TN210066 20160128T103017 Analysis of Efficiency Standards For Pool Pumps and Motors and

DOCKETED
Docket Number: 15-AAER-02

Project Title: Pool Pumps and Spa Labeling
TN #: 210066
Document Title: Analysis of Efficiency Standards for Pool Pumps and Motors, and Spas-
Draft Staff Report
Description: N/A
Filer: Sean Steffensen
Organization: California Energy Commission
Submitter Role: Commission Staff
Submission 1/28/2016 10:30:18 AM
Date:
Docketed Date: 1/28/2016
California Energy Commission
DRAFT STAFF REPORT
ANALYSIS OF EFFICIENCY
STANDARDS FOR POOL
PUMPS AND MOTORS,
AND SPAS
2015 Appliance Efficiency Pre-Rulemaking
Docket Number 15-AAER-02


Edmund G. Brown Jr., Governor
January 2016 | CEC-400-2016-002-SD

Ben Fischel
Sean Steffensen
Primary Authors
Elliot Bogart
Jessica Lopez
Bogdan Pishtoy
Research and Technical Support
Sean Steffensen
Project Manager
Kristen Driskell
Supervisor
Appliance Efficiency Program
Dave Ashuckian, P.E.

Deputy Director
EFFICIENCY DIVISION
Robert P. Oglesby
Executive Director
DISCLAIMER
Staff members of the California Energy Commission prepared this report. As such,
it does not necessarily represent the views of the Energy Commission, its
employees, or the State of California. The Energy Commission, the State of
California, its employees, contractors and subcontractors make no warrant, express
or implied, and assume no legal liability for the information in this report; nor does
any party represent that the uses of this information will not infringe upon
privately owned rights. This report has not been approved or disapproved by the
Energy Commission nor has the Commission passed upon the accuracy or
adequacy of the information in this report.
PREFACE
On March 14, 2012, the California Energy Commission issued an Order Instituting
Rulemaking to begin considering standards, test procedures, labeling requirements, and
other efficiency measures to amend the Appliance Efficiency Regulations (California Code of
Regulations, Title 20, Sections 1601 through Section 1609). In this Order, the Energy
Commission identified appliances with the potential to save energy and/or water. The goal
of the rulemaking is to develop proposed appliance efficiency standards and measures to
realize these savings opportunities.
On March 25, 2013, the Energy Commission released an “Invitation to Participate” to

provide interested parties the opportunity to inform the Commission about the product,
market, and industry characteristics of the appliances identified. The Commission reviewed
the information and data received, and hosted workshops on May 28 through 31, 2013, to
publicly vet this information.
On June 13, 2013, the Energy Commission released an “Invitation to Submit Proposals” to
seek proposals for standards, test procedures, labeling requirements, and other measures
to improve the efficiency and reduce the energy or water consumption of the identified
appliances.
On May 28, 2014, the Energy Commission released a notice to request additional
information from interested parties to develop standards for network equipment,
commercial clothes dryers, portable electric spas, and pool pumps and motors.
The Energy Commission reviewed all of the information received to determine which
appliances were candidates for efficiency standards and measures. This report contains the
proposed regulations for portable electric spas, and pool pumps and motors.
i
ABSTRACT
This report discusses proposed updates to the pool pumps and motors, and portable
electric spas standards in the Appliance Efficiency Regulations (California Code of
Regulations, Title 20, Sections 1601 to 1609). These proposed updates are part of the 2012
Appliance Efficiency Rulemaking, Phase I (Docket #15-AAER-02). California Energy
Commission staff analyzed the cost-effectiveness and technical feasibility of proposed
efficiency standards for pool pumps and motors, and portable electric spas. Statewide
energy use and savings, and related environmental impacts and benefits are also included.
Staff proposes two tiers of standards for single-speed, dual-speed, multi-speed, and
variable-speed motors sold in combination with pool pumps or sold separately as
replacements. The proposed Tier 1 standard would take effect on January 1, 2018, and Tier
2 would take effect on January 1, 2021, for all pool pump motors 5 hp or less. The
proposed standby power standard and label requirement for portable electric spas would
take effect on January 1, 2018. In addition, staff proposes to amend and add definitions,
and update test procedures so that the standards can be enforced effectively.
The proposed updates would save about 129 GWh the first year the standard is in effect. By
the year that stock turns over (2026), the proposed standards would have a combined
annual savings of about 1,320 GWh. This equates to roughly $211 million in annual savings
to California businesses and individuals. In addition, GHG would be reduced by 455
thousand tons of carbon dioxide equivalents annually.
Staff analyzed available market data and concluded that the updates to standards for pool
pumps and motors, and portable spas would significantly reduce energy consumption and
are technically feasible and cost-effective.
Keywords: Appliance Efficiency Regulations, appliance regulations, energy efficiency, pool

pumps and motors, portable electric spas.
Please use the following citation for this report:
Steffensen, Sean, Ben Fischel. 2016. Staff Analysis of Efficiency Standards for Pool Pumps
and Motors, and Spas. California Energy Commission. Publication Number: CEC-400-
2016-002-SD.
ii
TABLE OF CONTENTS
Page
Preface .......................................................................................................................................................... i
Abstract .......................................................................................................................................................ii
TABLE OF CONTENTS ............................................................................................................................ iii
List of Figures ............................................................................................................................................ vi
List of Tables ............................................................................................................................................ vii
Executive Summary .................................................................................................................................1
CHAPTER 1: Legislative Criteria ..............................................................................................................2
CHAPTER 2: Efficiency Policy ..................................................................................................................3

Reducing Electrical Energy Consumption to Address Climate Change ...................................... 3
Loading Order for Meeting the State’s Energy Needs ..................................................................... 4
Zero-Net-Energy Goals ........................................................................................................................... 4
Governor’s Clean Energy Jobs Plan ..................................................................................................... 5
Part A: Pool Pumps and Motors ............................................................................................................ 6
CHAPTER 3: Product Description ...........................................................................................................7

Overview of Pool Water Circulation System...................................................................................... 7
Pump and Motor Equipment Description .......................................................................................... 9
Pool Circulation System Energy Consumption .............................................................................. 10
Motor Energy Consumption and Efficiency ................................................................................... 12
Pool Pump and Motor Categories .................................................................................................................. 13
CHAPTER 4: Regulatory Approaches .................................................................................................. 16

Historical Approach ............................................................................................................................ 16
Federal Regulations ............................................................................................................................. 16
California Regulations ........................................................................................................................ 16
Regulations in Other States ............................................................................................................... 17
ENERGY STAR® ..................................................................................................................................... 17
The CASE Report .................................................................................................................................. 18
CHAPTER 5: Alternative Consideration .............................................................................................. 19

Alternative 1: Maintaining Current Title 20 Appliance Standards ............................................ 19
Alternative 2: Incorporate CASE Team Proposal........................................................................... 19
Alternative 3: Incorporate CASE Team Proposal with Tiered Motor Efficiency ..................... 21
Alternative 4: Incorporate CASE Team Proposal with Uniform Full Speed Efficiency for All
Motor Types ................................................................................................................................... 22
iii
CHAPTER 6: Staff Proposed Standards for Pool Pumps and Motor Combinations and
Replacement Pool Pump Motors .......................................................................................................... 24
Scope ...................................................................................................................................................... 24
Motor Efficiency ................................................................................................................................... 24
Tier 1 ................................................................................................................................................................... 24
Tier 2 ................................................................................................................................................................... 26
Remove Prohibition on Split-phase and Capacitor-start Induction Run Motors ................................. 28
New Proposed Pool Pump Motor Types ....................................................................................................... 29
Motor Efficiency Test Procedure ...................................................................................................... 29
Pump Efficiency Test Procedure ....................................................................................................... 29
CHAPTER 7: Savings and Cost Analysis ............................................................................................. 30
CHAPTER 8: Pool Pumps and Motors Standard Technical Feasibility ......................................... 34
Motor Efficiency ................................................................................................................................... 34
Conduction Losses ........................................................................................................................................... 34
Speed Losses...................................................................................................................................................... 35
Motor Efficiency Market Survey ..................................................................................................................... 36
Two or More Speed Pump Requirement ......................................................................................... 37
CHAPTER 9: Environmental Impacts .................................................................................................. 38

Impacts................................................................................................................................................... 38
Benefits .................................................................................................................................................. 38
CHAPTER 10: Regulatory Language .................................................................................................... 40
APPENDIX A: Staff Assumptions and Calculation Methods........................................................... 48

Stock and Sales ..................................................................................................................................... 48
Compliance Rates ................................................................................................................................ 49
Duty Cycle ............................................................................................................................................. 49
Baseline Energy Use ............................................................................................................................. 50
Compliant Energy Use......................................................................................................................... 57
Cost and Energy Savings .................................................................................................................... 58
Part B: Portable Electric Spas .............................................................................................................. 62
Chapter 11: Product Description ......................................................................................................... 63

Portable Spas ..................................................................................................................................................... 64
Exercise Spas ..................................................................................................................................................... 64
Heating System ..................................................................................................................................... 65
Pumping System................................................................................................................................... 67
Water Treatment .................................................................................................................................. 68
Insulation and Spa Covers ................................................................................................................. 69
Energy Use ............................................................................................................................................. 75
iv
Chapter 12: Regulatory Approaches ................................................................................................... 77
Current Title 20 Standards ................................................................................................................ 77
Federal Approaches ............................................................................................................................. 77
Other State Approaches ..................................................................................................................... 77
Industry Standards .............................................................................................................................. 77
The CASE Report .................................................................................................................................. 78
Chapter 13: Alternative Considerations............................................................................................. 79

Alternative 1: Maintaining Current Title 20 ................................................................................... 79
Alternative 2: Incorporate CASE Team Proposal........................................................................... 79
Alternative 3: Updated Standby Standards with Spa Cover Reporting and Labeling ........... 80
Chapter 14: Staff Proposed Standards for Portable Electric Spas and Exercise Spas .............. 81
Scope ...................................................................................................................................................... 81
Test Procedure...................................................................................................................................... 81
Standby Power Consumption ............................................................................................................ 82
Labeling Requirements ....................................................................................................................... 82
Spa Cover Labeling and Reporting Requirements ........................................................................ 85
Chapter 15: Savings and Cost Analysis .............................................................................................. 86

Incremental Costs ................................................................................................................................ 86
Standby Power Efficiency Savings .................................................................................................... 89
Spa Cover Savings ................................................................................................................................ 89
Spa Labeling Savings ........................................................................................................................... 90
Chapter 16: Technical Feasibility of Proposed Standards for Portable Electric Spas .............. 92
Insulation ............................................................................................................................................... 93
Spa Covers ............................................................................................................................................. 93
Pump and Motor .................................................................................................................................. 94
Chapter 17: Environmental Impacts ................................................................................................... 95

Environmental Impacts....................................................................................................................... 95
Benefits .................................................................................................................................................. 95
Chapter 18: Regulatory Language ....................................................................................................... 96
Appendix B: Staff Assumptions and Calculation Methods ............................................................ 99

Stock and Sales ............................................................................................................................................... 100
Design Life ....................................................................................................................................................... 102
Compliance Rates ........................................................................................................................................... 103
Duty Cycle ........................................................................................................................................................ 104
Baseline Energy Use ....................................................................................................................................... 104
Compliant Energy Use....................................................................................................................... 108
Cost and Savings ................................................................................................................................ 108
v
LIST OF FIGURES
Figure 1: Standard pool pump system installation schematic .........................................................7
Figure 2: Pool Plumbing System Complete with Filter, Heater, Skimmer, .....................................8
and Pump and Motor Combination ........................................................................................................8
Figure 3: Pool Pump and Motor Combination ................................................................................... 10
Figure 4: Replacement Pool Pump Motor ........................................................................................... 10
Figure 5: Electric motor types by power source and motor technology. .................................... 13
Figure 6: CASE Report Single-Speed Efficiency Standard ............................................................... 20
Figure 7: CASE Team Dual-Speed, Multi-speed, and Variable-Speed Efficiency Standard ....... 21
Figure 8: Comparison of Single-Speed Motor Efficiency Alternatives ......................................... 23
Figure 9: Tier 1 Single-Speed Motor Efficiency Standard ............................................................... 25
Figure 10: Tier 1 Full Speed and Half Speed Motor Efficiency Standard .................................... 26
Figure 11: Tier 2 Single-Speed Motor Efficiency Standard ............................................................. 27
Figure 12: Tier 2 Full-Speed and Half-Speed Motor Efficiency Standard .................................... 28
Figure 13: Efficiency Improvements with Additional Rotor and Stator Conductors ............... 35
Figure 14: Typical Components in a Portable Electric Spa............................................................. 64
Figure 15: Heating and Pumping System ........................................................................................... 66
Figure 16: Standard Jet Cross-Section ................................................................................................ 68
Figure 17: Water Treatment System in a Portable Electric Spa ..................................................... 69
Figure 18: Cross-Section of a Spa Cover ............................................................................................ 71
Figure 19: Radiant Barrier in a Spa Cover .......................................................................................... 73
Figure 20: Types of Spa Cover Enclosures ......................................................................................... 73
Figure 21: Dual-Hinge and Single-Hinge Spa Covers ....................................................................... 74
Figure 22: Spa Cover Skirt ..................................................................................................................... 74
Figure 23: Spa Floating Blanket ............................................................................................................ 75
Figure 24: Label Design .......................................................................................................................... 83
Figure 25: Label Specifications ............................................................................................................. 84
Figure 26: Portable Electric Spas in the MAEDBS ............................................................................. 92
Figure B-1: Maximum Allowable Standby Power per Zone ........................................................... 106
vi
LIST OF TABLES
Table 1: IOU Proposed Standards for Pool Pump Motors - Effective July 1, 2017 .................... 20
Table 2: Alternative 3, Tier I - Effective January 1, 2018 ............................................................... 22
Table 3: Alternative 3, Tier II - Effective January 1, 2021 .............................................................. 22
Table 4: Staff Proposed Alternative 4, Tier I - Effective January 1, 2018 ................................... 22
Table 5: Staff Proposed Alternative 4 Tier II Effective January 1, 2021. .................................... 23
Table 6: Tier I Proposed Standards for Pool Pump Motors............................................................ 25
Table 7: Tier 2 Proposed Standards for Pool Pump Motors........................................................... 26
Table 8: Annual Energy and Monetary Savings per Unit ................................................................ 30
Table 9: Tier 1 Statewide Annual Savings .......................................................................................... 32
Table 10: Tier 2 Statewide Annual Savings ....................................................................................... 33
Table 11: Tier 1 and Tier 2 Statewide Annual Savings ................................................................... 33
Table 12: Single-Speed Pool Pump Motor Performance .................................................................. 36
of Motors in Energy Commission Database - June 2015 ................................................................ 36
Table 13: Dual-Speed Pool Pump Motor Performance in Energy Commission Database - June
2015 ........................................................................................................................................................... 36
Table 14: Variable-Speed Pool Pump Motor Performance of ......................................................... 36
Motors in Energy Commission Database - June 2015 ..................................................................... 36
Table 15: Criteria and Greenhouse Gas Emissions Reductions ................................................... 39
Table A-1: Stock and Sales .................................................................................................................... 48
Table A-2: Compliance Rates ................................................................................................................ 49
Table A-3: Duty Cycle ............................................................................................................................. 50
Table A-4: Tier 1 Baseline Energy Consumption .............................................................................. 52
Table A-5: Tier 2 Baseline Energy Consumption .............................................................................. 53
Table A-6: Sales Weight Data ................................................................................................................ 54
Table A-7: Tier 1 Efficiency and Compliance Data .......................................................................... 55
Table A-8: Tier 2 Efficiency and Compliance Data .......................................................................... 56
Table A-9: Tier 1 Compliant Energy Consumption .......................................................................... 57
Table A-10: Tier 2 Compliant Energy Consumption........................................................................ 58
Table A-11: Tier 1 Statewide Cost and Energy Savings ................................................................... 59
Table A-12: Tier 2 Statewide Cost and Energy Savings ................................................................... 59
Table A-13: Tier 1 and Tier 2 Statewide Cost and Energy Savings ............................................... 60
Table A-14: Annual Energy and Monetary Savings .......................................................................... 61
Table 16: Evaporation Rate Without a Spa Cover............................................................................. 70
Table 17: Annual Energy and Water Waste Without a Spa Cover ................................................. 71
Table 18: Percent Contributions to the Total Standby Power by Cycle Type ............................ 76
Table 19: Estimated Incremental Costs for Current Standard ...................................................... 87
Table 20: Label Costs for Portable Electric Spas .............................................................................. 88
Table 21: Weighted Unit Energy Savings and Lifecycle Benefits ................................................... 88
Table 22: Standby Power Standard Statewide Annual Stock Savings .......................................... 89
Table 23: Energy Cost for Uncovered Spa.......................................................................................... 89
Table 24: Statewide Annual Stock Savings Adjusting for Label Impact ...................................... 91
vii
Table 25: Compliance Rate of Portable Electric Spas ...................................................................... 93
Table 26: Greenhouse Gas Emissions Reductions ........................................................................... 95
Table X – Data Submittal Requirements ............................................................................................ 98
Table B-1: Summary of Values and Assumptions .......................................................................... 100
Table B-2: Number of Portable Electric Spa Units in California ................................................. 101
Table B-3: Outdoor and Above-ground Spas in California ........................................................... 101
Table B-4: Estimated Annual Stock and Sales ................................................................................. 102
Table B-5: Estimated Design Life of Non-Inflatable, Portable Electric Spas ............................. 102
Table B-6: Compliance Rate for Portable Electric Spas ................................................................. 103
Table B-7: Unit Population and Compliance Rate for each Zone ................................................ 103
Table B-8: Duty Cycle ........................................................................................................................... 104
Table B-9: Average Volume used for Calculations ......................................................................... 105
Table B-10: Baseline Energy Consumption without label savings .............................................. 107
Table B-11: Baseline Energy Use ........................................................................................................ 108
Table B-12: Compliant Energy Use .................................................................................................... 108
Table B-13: Standby Power Standard Statewide Annual Stock Savings ..................................... 109
Table B-14: Statewide Annual Stock Savings Adjusting for Label Impact ................................ 109
Table B-15: Percentage of Energy Consumption after Applying the Standby Power Standard
.................................................................................................................................................................. 110
Table B-16: Weighted Unit Energy Savings and Lifecycle Benefits/Costs ................................. 111
Table B-17: Evaporation Rate without a Spa Cover........................................................................ 112
Table B-18: Total Energy and Power Required to Heat Evaporated Water................................ 113
Table B-19: Annual Energy and Water Consumption .................................................................... 114
viii
EXECUTIVE SUMMARY
The California Energy Commission proposes to create significant energy efficiency

opportunities for pool pump motors and portable electric spas through Title 20 standards. The
following Appliance Efficiency Program analysis provides support for the proposed standards.
Staff analysis demonstrates that the proposed pool pump motor and portable electric spa
standards are technically feasible for the industry and cost-effective for consumers. After full
stock turnover, the proposed standards combine for an estimated 1,320 GWh of statewide
energy savings per year.
Staff is proposing to expand the existing scope of pool pump and motor combinations (pump
and motor packaged together), and replacement pool pump motors (standalone motors) that
are used for filtration and circulation, water features and waterfalls, and as booster pumps. The
proposal includes modifications and additions to the pool pump and motor definitions to meet
the new scope expansion and ensure that the standards can be enforced effectively. Test
procedures are proposed for all pool motors from CSA 747-09 and for all pool pumps from
ANSI/HI-14.6 2011.
Two tiers of standards are proposed for single-speed, dual-speed, multi-speed, and variable-
speed motors sold in a combination with pool pumps or sold separately as replacements.
During Tier 1, the proposed minimum efficiency requirement for single-speed motors at full
speed shall be 70 percent; and for variable-speed, multi-speed, and dual-speed motors at full
speed and at half speed, shall be 70 percent and 50 percent, respectively. When Tier 2 begins,
the proposed minimum efficiency requirement for single-speed motors at full speed shall be 80
percent; and for variable-speed, multi-speed, and dual-speed motors at full speed and at half
speed, shall be 80 percent and 65 percent, respectively. The proposed Tier 1 standard would
take effect on January 1, 2018, and the Tier 2 standard would take effect on January 1, 2021,
for all pool pump motors that are 5 hp or less. The proposed standards would result in an
estimated 117 GWh of first-year energy savings and an estimated 1,778 GWh of energy savings
after full stock turnover.
New standards for portable electric spas are also proposed. The scope includes all types of
portable electric spas, such as exercise spas, combination spas, swim spas, and inflatable spas.
Staff proposes to adopt the ANSI/APSP/ICC-14 2014 standby power standard, new test
requirements, and label requirements. The standby power standard will tighten power
consumption on larger spas while providing modest relief on smaller spas. The test method
provides elaboration on test setup and measurements. The label standard requires
manufacturers to display the standby power and list the spa cover that was used during testing
to achieve the reported standby power. The label requirement will help consumers make
informed choices based on energy, boosting energy savings. The proposed standards would
take effect on January 1, 2018. The estimated standby power savings after complete stock
turnover is 61 GWh with $10 million in cost savings. The label requirement will have an
additional estimated 80 GWh of energy savings with $13 million of cost savings after complete
stock turnover.
1
CHAPTER 1: Legislative Criteria
Section 25402(c)(1) of the California Public Resources Code mandates that the California Energy
Commission reduce the inefficient consumption of energy and water by prescribing efficiency
standards and other cost-effective measures1 for appliances that require a significant amount of
energy and water to operate on a statewide basis. Such standards must be technologically
feasible and attainable, and must not result in any added total cost to the consumer over the
designed life of the appliance.
In determining cost-effectiveness, the Energy Commission considers the value of the water or
energy saved, the effect on product efficacy for the consumer, and the life-cycle cost to the
consumer of complying with the standard. The Commission also considers other relevant
factors including, but not limited to, the effect on housing costs, the total statewide costs and
benefits of the standard over the lifetime of the standard, the economic impact on California
businesses, and alternative approaches and the associated costs.
1 These include energy and water consumption labeling, fleet averaging, incentive programs, and consumer education
programs.
2
CHAPTER 2: Efficiency Policy
The Warren-Alquist Act2 establishes the Energy Commission as California’s primary energy
policy and planning agency and mandates that the Commission reduce the wasteful and
inefficient consumption of energy and water in the state by prescribing standards for minimum
levels of operating efficiency for appliances that consume a significant amount of energy or
water statewide.
For nearly four decades, appliance standards have shifted the marketplace toward more
efficient products and practices, reaping large benefits for California’s consumers. The state’s
appliance efficiency regulations saved an estimated 22,923 GWh of electricity and 1,626 million
therms of natural gas in 20123 alone, resulting in about $5.24 billion in savings to California
consumers in 2012 from these regulations4. Since the mid-1970s, California has regularly
increased the energy efficiency requirements for new appliances sold and new buildings
constructed in the state. In the 1990s, the CPUC de-coupled the utilities’ financial results from
their direct energy sales, facilitating utility support for efficiency programs. These efforts have
reduced peak load needs by more than 12,000 MW and continue to save about 45,519 GWh per
year of electricity5. Still, there remains huge potential for additional savings by increasing the
energy efficiency and improving the use of appliances.
Reducing Electrical Energy Consumption to Address Climate

Change
Appliance energy efficiency is identified as a key to achieving the GHG emission reduction goals
of Assembly Bill 32 (Núñez, Chapter 488, Statutes of 2006)6 (AB 32), as well as the
recommendations contained in the ARB’s Climate Change Scoping Plan7. Energy efficiency
regulations are also identified as key components in reducing electrical energy consumption in
the Energy Commission’s 2013 Integrated Energy Policy Report (IEPR)8 and the 2011 update to
the CPUC’s Energy Efficiency Strategic Plan9. Finally, Governor Brown identified reduced energy
2 The Warren-Alquist State Energy Resources Conservation and Development Act, Division 15 of the Public Resources
Code, § 25000 et seq, available at http://www.energy.ca.gov/2015publications/CEC-140-2015-002/CEC-140-2015-
002.pdf.
3 California Energy Commission. California Energy Demand 2014‐2024 Revised Forecast, September 2013, available at
http://www.energy.ca.gov/2013publications/CEC-200-2013-004/CEC-200-2013-004-V2-CMF.pdf.
4 Using current average electric power and natural gas rates of: residential electric rate of $0.164 per kilowatt-hour,
commercial electric rate of $0.147 per kilowatt-hour, residential gas rate of $0.98 per therm, and commercial gas rate of
$0.75 per therm. This estimate does not incorporate any costs associated with developing or complying with appliance
standards.
5 California Energy Demand 2014-2024 Final Forecast available at
http://www.energy.ca.gov/2013publications/CEC-200-2013-004/CEC-200-2013-004-V2-CMF.pdf, p. 86.
6 AB 32, California Global Warming Solutions Act of 2006, available at
http://www.leginfo.ca.gov/pub/05‐06/bill/asm/ab_0001‐0050/ab_32_bill_20060927_chaptered.html.
7 Climate Change Scoping Plan available at
http://www.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf.
8 California Energy Commission, 2013 Integrated Energy Policy Report, January 2014, available at
http://www.energy.ca.gov/2013publications/CEC‐100‐2013‐001/CEC‐100‐2013‐001‐CMF.
9 CPUC, Energy Efficiency Strategic Plan, updated January 2011, available at
3
consumption through efficiency standards as a key strategy for achieving his 2030 GHG
reduction goals10.
Loading Order for Meeting the State’s Energy Needs

California’s loading order places energy efficiency as the top priority for meeting the state’s
energy needs. Energy Action Plan II continues the strong support for the loading order, which
describes the priority sequence for actions to address increasing energy needs. The loading
order identifies energy efficiency and demand response as the preferred means of meeting
growing energy needs11.
For the past 30 years, while per capita electricity consumption in the United States has
increased by nearly 50 percent, California electricity use per capita has been nearly flat.
Continued progress in cost-effective building and appliance standards and ongoing
enhancements to efficiency programs implemented by investor-owned utilities (IOUs), publicly
owned utilities, and other entities have significantly contributed to this achievement12.
Zero-Net-Energy Goals
The California Long‐Term Energy Efficiency Strategic Plan13, adopted in 2008 by the CPUC, and
developed with the Energy Commission, the ARB, the state’s utilities, and other key
stakeholders, is California’s roadmap to achieving maximum energy savings in the state
between 2009 and 2020, and beyond. It includes four “big bold strategies” as cornerstones for
significant energy savings with widespread benefit for all Californians14:
 All new residential construction in California will be zero-net-energy (ZNE) by 2020.

 All new commercial construction in California will be ZNE by 2030.
 HVAC will be transformed to ensure that energy performance is optimal for California’s
climate.
 All eligible low-income customers will have the opportunity to participate in the low-
income energy efficiency program by 2020.
These strategies were selected based on their ability to achieve significant energy efficiency
savings and bring energy-efficient technologies and products into the market.
http://www.cpuc.ca.gov/NR/rdonlyres/A54B59C2-D571-440D-9477-
3363726F573A/0/CAEnergyEfficiencyStrategicPlan_Jan2011.pdf.
10 Gov. Edmund G. Brown Jr., 2015 Inaugural Address, available at http://gov.ca.gov/news.php?id=18828
11 Energy Action Plan II, available at http://www.energy.ca.gov/energy_action_plan/2005-09-21_EAP2_FINAL.PDF , p. 2.
12 Energy Action Plan II, available at
http://www.energy.ca.gov/energy_action_plan/2005-09-21_EAP2_FINAL.PDF, p. 3.
13 California Energy Commission and CPUC, Long‐Term Energy Efficiency Strategic Plan, updated January 2011,
available at http://www.cpuc.ca.gov/NR/rdonlyres/A54B59C2-D571-440D-9477-
3363726F573A/0/CAEnergyEfficiencyStrategicPlan_Jan2011.pdf.
14 California Energy Commission and CPUC, Long-Term Energy Efficiency Strategic Plan, available at
http://www.cpuc.ca.gov/NR/rdonlyres/14D34133-4741-4EBC-85EA-8AE8CF69D36F/0/EESP_onepager.pdf , p. 1.
4
On April 25, 2012, Governor Brown further targeted ZNE consumption for state-owned
buildings. Executive Order B-18-1215 requires ZNE consumption for 50 percent of the square
footage of existing state-owned buildings by 2025 and ZNE consumption from all new or
renovated state buildings beginning design after 2025.
To achieve these goals, the Energy Commission has committed to adopting and implementing
building and appliance regulations that reduce wasteful energy and water consumption. The
Long-Term Energy Efficiency Strategic Plan directs the Commission to develop a phased and
accelerated “top-down” approach to more stringent codes and standards16. It also calls for
expanding the scope of appliance standards to plug loads, process loads, and water use. The
Commission adopted its detailed plan for fulfilling these objectives in the 2013 IEPR17.
Governor’s Clean Energy Jobs Plan

On June 15, 2010, as a part of his election campaign, Governor Brown proposed the Clean
Energy Jobs Plan18, which directed the Energy Commission to strengthen appliance efficiency
standards for lighting, consumer electronics, and other products. The Governor noted that
energy efficiency is the cheapest, fastest, and most reliable way to create jobs, save consumers
money, and cut pollution from the power sector. He stated that California's efficiency standards
and programs have triggered innovation and creativity in the market. Today's appliances are
not only more efficient, but they are cheaper and more versatile than ever due, in part, to
California’s leadership in the area.
15 Office of Edmund G. Brown Jr., Executive Order B-18-12, April 25, 2012, available at
http://www.gov.ca.gov/news.php?id=17506http://gov.ca.gov/news.php?id=17506.
16 California Energy Commission and CPUC, Long-Term Energy Efficiency Strategic Plan, p. 64.
17 California Energy Commission, 2013 IEPR, pp. 21-26.
18 Office of Edmund G. Brown Jr., Clean Energy Jobs Plan, available at http://gov.ca.gov/docs/Clean_Energy_Plan.pdf.
5
PART A: POOL PUMPS AND MOTORS
6
CHAPTER 3: Product Description
Overview of Pool Water Circulation System

The pool water circulation system incorporates the technological advances in filtering and
chlorination first introduced to reduce frequent outbreaks in waterborne illness in the drinking
supply system. Pool users demand that pool water be clean and clear, and that the water be free
of disease-causing pathogens such as typhoid, dysentery, and cholera. The pool circulation
system provides the essential functions to meet both aesthetic and safety requirements19.
A pool pump and motor combination circulates pool water through a filter and ensures
adequate chlorination to maintain clarity and sanitation. The filter removes dirt, leaves, hair,
insects, and other debris. The heater maintains the water temperature, and the chlorinator adds
sanitizing disinfectants, oxidizers, and algaecides. A search of online pool pump and motor
vendors shows many recommend that residential pool systems be designed to circulate the
entire pool water volume in 8 to 12 hours20,21,22. Commercial pool systems are designed to
complete circulation or turnover in 6 hours due to their higher level of use23. A common pool
system configuration including these components can be seen in Figure 1.
Figure 1: Standard pool pump system installation schematic
Source: epoolshop.com
Pool maintenance programs are typically broken up into filtering, heating, and cleaning
applications. An in-ground spa will require an additional application to provide high speed jets
for spa massage. These maintenance applications as well as the pool equipment types, pool
plumbing design, and pool volume influence the pool pump and motor sizing.
19 The History of Drinking Water Treatment, U.S. EPA Feb, 2000, available at
http://www.epa.gov/safewater/consumer/pdf/hist.pdf.
20 Hayward Hydraulics and Pump Sizing for Existing Pools, Hayward Industries, 2011, p. 7, available at
http://www.nuccibros.com/sec_0934drRb_dl/data_sheets/Hydraulics%20%20and%20Pump%20Sizing%20for%20Existing
%20Pools%20Guide.pdf.
21 How to Size a Pool Pump for Your In-Ground Pool, INYO Pools, 2015, available at
http://www.inyopools.com/HowToPage/how_to_size_a_pool_pump_for_your_in_ground_pool_.aspx.
22 Pool Pump Sizing, poolplaza.com, 2015, available at https://www.poolplaza.com/pool-pump-sizing.
23 California Health and Safety Code Sections 116064.2 (b) (2) (E).
7
Filtering is the primary maintenance task for pools. A filtering time should be selected that will
ensure adequate water turnover (the entire pool water volume will be filtered once per day).
Significant energy and cost savings can be achieved if the pump is set to the lowest possible
speed that will result in complete water filtration. In addition, at lower speeds, the filtration
system will more completely clean the water as less water will bypass the filter at lower flow
rates.
The heater task requires a minimum flow rate to ensure efficient heat transfer within the
heating system and to protect against overheating. A moderate to high flow rate should be
selected according to the heater guidelines.
The cleaning and in-ground spa tasks require the highest flow. The cleaning task provides a
high flow rate into the pool to stir up settled debris so that it is captured by the filter. The jet
task in in-ground spa applications also requires a high flow to provide the user with a
therapeutic massage. The cleaning and jet tasks are typically shorter in duration than the pool
filtering task.
Figure 2: Pool Plumbing System Complete with Filter, Heater, Skimmer,

and Pump and Motor Combination
Illustration Credit: Staff Illustration
The pool pump motor combination may also be called upon to provide water flow to the pool
sweeper and vacuum, and to run water features such as a waterfall or fountain. Motors used in
these applications are run at full speed for longer durations, resulting in substantial energy
consumption24.
24 U.S. DOE, Measure Guideline: Replacing Single-Speed Pool Pumps with Variable Speed Pumps for Energy Savings, pp.
2-3, available at http://www.nrel.gov/docs/fy12osti/54242.pdf.
8
A pool owner can achieve significant energy savings by running the pool pump and motor
combination at the lowest available motor speed that meets the task’s minimum water flow
requirements25. Different motor technologies exist to allow the consumer to select the speed
adequate to the pool maintenance task to achieve energy savings. Variable-speed pool pump
and motor combinations provide the most flexibility and provide the greatest savings. Dual-
speed motors provide a low-speed choice to enable savings for the pool filtering task. Single-
speed pool pump and motors require all pool maintenance tasks to be run at full speed and do
not provide a choice in motor speeds.
Pump and Motor Equipment Description

The pool pump relies on an end suction centrifugal rotor design to move the water through the
system. The pump draws water through the center of the pump’s impellor and generates a
pressure force sufficient to overcome flow resistance in the pool’s plumbing system. The
pressure head forces the water through the pool’s plumbing, filtering equipment, and heater.
Pool pumps use end suction centrifugal pump designs exclusively due to their low initial cost,
low complexity, and moderate energy efficiency when compared to double suction centrifugal
pumps or positive displacement pumps26.
An electric motor powers the pump by converting electrical energy to rotational energy. The
electric motor is typically sized between 0.1 and 5.0 nameplate hp. The motor may provide
single-speed, dual-speed, multiple-speed, or variable-speed operation depending upon the
electric motor design.
Pool pump and motor combinations are typically sold when a consumer installs a pool or
upgrades an existing pool pump and motor combination from a single-speed to a dual-speed or
variable-speed system. Pool pump and motor combinations are also sold with above ground
storable pools. As a low cost alternative, electric motor manufacturers sell replacement pool
pump motors since the motor typically fails before the pump. Electric motors used in pool
pump applications have a lifetime expectancy of about 10 years. Replacement pool pump
motors are included within the scope of this report. Figure 3 shows a typical pool pump and
motor combination. Figure 4 shows a typical replacement pool pump motor.
25 Variable Speed Pumping, A Guide to Successful Applications, Executive Summary, pp. 4-5 available at
http://www.energy.gov/sites/prod/files/2014/05/f16/variable_speed_pumping.pdf.
26 Improving Pumping System Performance, A Sourcebook for Industry, U.S. DOE Second Edition, pp. 13-14, available at
http://energy.gov/sites/prod/files/2014/05/f16/pump.pdf.
9
Figure 3: Pool Pump and Motor Combination
Source: Hayward Pools
Figure 4: Replacement Pool Pump Motor
Source: Century A.O. Smith
Pool Circulation System Energy Consumption

The pool circulation energy consumption consists of the energy dissipated by the circulation
process since the pool water begins and ends in the same location. The pool water is drawn
from the pool, pushed through the plumbing system and returned to the pool. The energy is
10
dissipated by energy losses in the electrical motor and frictional losses within the plumbing
system.
The total energy consumption of a pool circulation system depends on the motor efficiency, the
pump efficiency, pool plumbing configuration, and the options available to the user to select
pump motor speed and run time.
In-ground public swimming pool and plumbing configurations are regulated by California
Health and Safety Code (Sections 116025 through 116068) and California Building Code, Title
24, Part 2 (Sections 3101B through 3162). Residential in-ground and above-ground swimming
pools and spas are regulated by California Building Code, Title 24, Part 6 (Sections 110.4 and
150.0 (p)). The requirements control the design of new pools and the significant retrofit of
existing in-ground public swimming pools and residential in-ground swimming pools and spas
to ensure safe and energy efficient pools, and pool maintenance. The regulations control the
placement of pool inlets and outlets, skimmers and drains, pipe sizing, and the use of pipe
elbows. The pool system configuration requirements are outside the scope of the Title 20
Appliance Efficiency Standards, but understanding them is relevant to determining the
representative energy performance of the pool pump and motor.
The energy dissipated in the plumbing system is proportional to the speed or flow rate that the
water is pushed through plumbing system27. The energy loss phenomenon is similar to the
energy losses encountered by a car from wind resistance. Just as a car will achieve better fuel
economy at lower speeds by reducing the wind resistance, a pool system will achieve greater
efficiency by reducing the resistance in the plumbing system at lower flow rates. The
phenomenon is described by the three pump affinity laws shown below that are applicable to a
wide field of systems utilizing pumps and fans, and including pool circulation systems. The
laws describe how varying the pump rotational speed affects the flow rate, pressure, and power
performance of a pump system.
Pump Affinity Law 1 Flow Rate (gallon per minute)

q1/q2 = (n1/n2)
where q = volume flow rate (gpm,) and n = Motor Speed - revolution per minute (rpm)
Pump Affinity Law 2 Head or Pressure (psi)

h1/h2 = (n1/n2)2
where h = head or pressure (psi)
Pump Affinity Law 3 Power (kW or hp)

P1/P2 = (n1/n2)3
where P = power (kW, hp)
27 U.S. DOE, Measure Guideline: Replacing Single-Speed Pool Pumps with Variable Speed Pumps for Energy Savings, pp.
3-4, available at http://www.nrel.gov/docs/fy12osti/54242.pdf.
11
Energy Consumption (kWh)
Energy = Power × time
According to the pump affinity laws, there is a cubic relationship between the power
requirement of the motor and the rotational speed of the attached pump. Therefore, if a pump
rotor speed were reduced to one half of its maximum, the electrical power demanded by the
motor would be reduced to one eighth of its maximum. The pump affinity laws also state that
the volumetric flow rate is directly proportional to the speed of the motor. For example, the
volumetric flow rate through a pump would be reduced by half if the rotational speed of the
attached pump is reduced by half28. To achieve the same volume of flow the pump must be run
twice as long at half speed. The total energy consumed then, as defined by power multiplied by
time, is 25 percent of the energy to move the same quantity of water at the pump’s full speed.
Substantial energy savings can be realized by running the motor at the lowest speed adequate
to meet the needs of the pool maintenance application.
Motor Energy Consumption and Efficiency

The electric motor’s type, design, and size determine the motor’s efficiency. Motor types for
pool circulation applications include single-phase alternating current (AC) induction, three-
phase AC induction, and electrically-commutated brushless motors. Smaller above-ground
pools utilize permanent magnet synchronous pool pump motors. Single-phase AC induction
motors can achieve full speed efficiencies between 64 and 83 percent, and three-phase
induction AC and electronically commutated motors can achieve full speed efficiencies between
77 and 92 percent29. Three-phase AC induction motors are more energy efficient than single-
phase induction motors although their application is limited to sites that have three-phase
electrical service. Different motor types are summarized by power type and motor technologies
as seen in Figure 5. The ranges of efficiency and differences between motor types are discussed
in Chapter 8.
28 Pump Affinity Laws, The Engineering Toolbox, available at http://www.engineeringtoolbox.com/affinity-laws-

d_408.html.
29 Average motor efficiency of models found in the Appliance Efficiency Database of Title 20 compliant pool pump
motors.
12
Figure 5: Electric motor types by power source and motor technology.
Source: Small Motors and Motion Association
Pool Pump and Motor Categories
Single-Speed Pumps
Single-speed pool pumps are powered by single-phase or three-phase AC induction motors. The
motor design requires full-speed operation at the pump’s highest flow and pressure capacity.
Single-speed pumps cost significantly less and are simpler to install and control than dual-,
multiple-, or variable-speed pumps. Due to the simplicity of installation and low cost, the
majority of pool pump motors in California are single-speed motors30. Single-speed pumps are
the least energy efficient pool pump type because the pump and motor must be run at full
speed for all pool operations. Single-speed pump and motors dominate the pool pump market
even as more energy efficient designs are mandated by regulation31. Single-speed pump and
30 Eaton, Eileen, CEE High Efficiency Residential Swimming Pool Initiative, December 2012, pp. 18-19.
31 CASE Report, Analysis of Standards Proposal for Residential Swimming Pool & Portable Spa Equipment, pp. 20-22,
available at http://www.energy.ca.gov/appliances/2013rulemaking/documents/proposals/12-AAER-
13
motors persist in the market due to a lack of awareness among consumers and contractors
regarding the regulation and energy savings of more efficient pump designs. An additional
barrier is a need to educate pool contractors on how to select, install, and configure non single-
speed pump systems to achieve energy savings while maintaining pool cleanliness32.
Dual-/Multiple-Speed Pumps
Dual-speed pump motors are powered by single-phase AC induction motors. The motor design
allows for dual-speed operation at the pump and motor’s full and half speeds. At full speed,
equivalent to a single-speed pump operation, the pump generates its highest flow and pressure,
but this is the least energy efficient operational speed due to higher frictional losses within the
pools’ plumbing system. The pool’s cleaning and vacuuming tasks require full-speed pump and
motor operation to agitate and remove debris as effectively as possible. The pool’s circulation
for filtration tasks requires less flow and pressure, making the half-speed operation suitable for
these tasks33. The lower operating speed results in more energy efficient operation because
losses within the pool plumbing system are minimized. While the pump will need to operate
twice as long to move the same quantity of water, the power consumption during this time will
be 1/8, resulting in roughly 75 percent energy savings over full speed operation. Multiple-speed
pump motors are similar in construction to dual-speed pump motors, but allow the user to
select from three or more set speeds, rather than just half speed and full speed. The multiple
speed pump may allow a user to select a more suitable and lower power pump speed for the
task and thereby provide more savings.
Variable-Speed Pumps
Variable-speed pump motors are powered by electronically commutated motors (ECM) that
allow a user to select a speed most appropriate for the pool maintenance task. Electronics on
board the motor modify the incoming AC current and commutate the current to a three-phase
waveform to set the motor speed and minimize electrical losses within the motor. A variable-
speed motor may provide speeds between a minimum of 1/8 of full speed to full speed34.
A variable-speed pool pump motor accrues energy savings exceeding dual- and multiple-speed
motors in two ways. First, the user may select a speed slower than half speed or the lowest set
speed on a multiple-speed motor to accomplish the pool’s circulation and filtering tasks,
resulting in energy savings. In addition, the slower speeds achieved by variable-speed motors
2F_Residential_Pool_Pumps_and_Replacement_Motors/California_IOUs_Response_to_the_Invitation_to_Submit_Proposa
ls_for_Pool_and_Spas_2013-07-29_TN-71756.pdf.
32 Eaton, Eileen, CEE High Efficiency Residential Swimming Pool Initiative, Consortium for Energy Efficiency, Inc., Dec.
2012, pp. 18-20.
33 Davis Energy Group, Analysis of Standards Options for Residential Pool Pumps, Motors, and Controls, pp. 11-12,
available at http://consensus.fsu.edu/FBC/Pool-Efficiency/CASE_Pool_Pump.pdf.
14
offer quieter operation and longer service life than can be achieved at half speed with a dual-
speed motor.
Second, variable-speed motors utilize a permanent magnet rotor design that replaces the
electro-magnetic rotor design in AC induction motors. The variable-speed motor achieves
greater efficiency than the AC induction motor while running at the same speed because no
current is required to power the rotor magnet, as is required by the AC induction motor35.
35 Machine Design, The difference between AC induction, permanent magnet, and servomotor technologies, available at
http://machinedesign.com/motorsdrives/difference-between-ac-induction-permanent-magnet-and-servomotor-
technologies.
15
CHAPTER 4: Regulatory Approaches
Historical Approach
The California Energy Commission did not regulate pool pumps and motors before 2004. Most
pool pump and motor systems used single-speed motors with some systems utilizing fairly
inefficient electric motor types. In 2004, the Energy Commission adopted standards for
residential pool pumps and motors, which included a prohibition on inefficient split-phase or
capacitor-start induction electric motors, and a requirement that all pumps and motors that
have a total of 1 hp or greater provide at least two-speed operation and controllers. The 2004
standards prohibition on split-phase or capacitor-start induction motors took effect in January
2006 and the two-speed requirements for pool pump motors 1 hp or greater took effect in
January 2008.
In 2008, the Energy Commission adopted revisions to the 2004 standards, which included a
requirement that motors 1 hp or greater, manufactured after January 2010, shall be capable of
at least two speeds or be of variable-speed design. The scope of the regulation was expanded to
include replacement residential pool pump motors36.
The regulation has required that manufacturers test and certify all pool pump and motor
combinations and replacement pool pump motors sold or offered for sale in California. The
testing included motor efficiency and pump performance along three hydraulic system curves,
A, B, and C, intended to simulate the types of pools found in California.
Federal Regulations
At the current time, there are no federal standards for pool pumps and motors.
The U.S. DOE released a Request for Information for dedicated-purpose pool pumps on May 8,
2015, (80 Fed. Reg. 26475), resulting from negotiations during its commercial and industrial
pumps rulemaking. Among other things, the Request seeks to define dedicated-purpose pool
pumps and asks whether a negotiated rulemaking is feasible.
California Regulations
The 2013 California Building Code set standards to regulate the construction and operation of
public swimming pools. Both regulations require that the pool circulation system must achieve
36 Chrisman, Betty, Harinder Singh, Gary Flamm, and William Staak, Proposed Amendments to the Appliance Efficiency
Regulations, Dec. 2008, p. 2, available at http://energy.ca.gov/2008publications/CEC-400-2008-021/CEC-400-2008-021-
15DAY.pdf.
16
a six-hour turnover time, and that the circulation volume during in-use periods not fall below
65 percent of the six-hour turnover time37.
The Energy Standards (Title 24, Part 6) incorporate the Title 20 requirements for pool pumps
and motor combinations and provide further requirements for sizing the pumping equipment
based upon pool size. The standard requires pool pump and motor combinations over 1 hp to
be multiple-speed. The Building Efficiency Standards place requirements on system piping,
filters, and valves to ensure energy efficient operation38.
Regulations in Other States

Arizona enacted Title 44, Section 1375.02 (B) (2), Pool and Spa Energy Requirements, that
require all pool pumps and pool pump motors to be certified in the Association of Pool and Spa
Professionals’ database or the Energy Commission database. The regulation carries the same
prohibition on motor types as well as the requirement for two speeds for motors above 1 total
hp as California regulation. The law became effective January 1, 2012.
Florida enacted Florida Building Code, Section 403.9.4, that carries the same prohibition on
motor types as well as the requirement for two speeds for motors above 1 total hp. The law
provides an exception for the default low speed operation during periods of high solar heat
gain. The law also requires compliance with national energy standards ANSI/APSP 15 for
residential pools and in-ground spas for new construction. The law became effective December
31, 2011.
Washington enacted Washington Building Code, Section 403.9.4, that carries the same
prohibition on motor types as well as the requirement for a minimum of two speeds for motors
above 1 total hp. The law became effective January 1, 2010.
Connecticut and New York have adopted residential pool pump standard similar to the
California Title 20 regulations39.
The states of Texas, Nevada, Michigan, Oregon, and New Jersey have considered legislative bills
to adopt standards similar to the California Title 20 regulations for pools and spas40.
ENERGY STAR®
ENERGY STAR, a partnership program of the U.S. EPA, collaborates with stakeholders to
establish voluntary specifications for efficient appliances; among them are pool pumps and
motors.
37 California Building Code. Title 24, Chapter 31B, Sections 3101B – 3162, available at
http://www.ecodes.biz/ecodes_support/free_resources/2013California/13Building/PDFs/Chapter%2031B%20-
%20Public%20Swimming%20Pools.pdf.
38 Energy Commission Building Standard Section 150.0 (N) Pool Systems and Equipment Installation, available at
http://www.energy.ca.gov/2012publications/CEC-400-2012-004/CEC-400-2012-004-CMF-REV2.pdf.
39 http://library.cee1.org/sites/default/files/library/9986/cee_res_swimmingpoolinitiative_07dec2012_pdf_10557.pdf.
40 http://www.poolspanews.com/legislation/states-introduce-out-of-date-energy-laws.aspx.
17
ENERGY STAR rates pool pump and motor combinations on an energy factor basis. The U.S. EPA
defines energy factor as the volume of water pumped in gallons per watt hour of electric energy
used. The U.S. EPA uses test procedures and hydraulic system curves to measure the pump and
motor combination’s performance identical to the California Title 20 regulation. Testing is
required along system curves A, B, and C. Manufacturers must meet the energy factor criteria
for performance measured on system curve A. Single-speed pump and motor combinations are
tested at full speed while multi-speed, dual-speed, and variable-speed pump and motor
combinations are measured at the most efficient speed41. Products must achieve an energy
factor of at least 3.8 at low speed to meet the ENERGY STAR product specification. An energy
factor of 3.8 was chosen to encourage the sale of dual-speed or variable-speed pool pump and
motor combinations42.
The CASE Report

In July 2013, the California IOUs submitted a Codes and Standards Enhancement (CASE) report
to the Energy Commission in response to the Commission’s invitation to submit proposals43. In
September 2014, the IOUs submitted a revised proposal for pool pump standards44. In general,
the proposal recommends that the current prescriptive standards be replaced with
performance standards for all pool pump and motor combinations and replacement motors
that are less than 5 hp by adding minimum efficiency requirements, measured at full speed and
half speed. The proposal recommends the use of the Canadian Standards Association (CSA)
test procedure C747-09 to verify compliance for motor efficiency.
The CASE team estimates the proposed standard would result in 63 GWh of energy savings in
the first year and 630 GWh of energy savings each year after full stock turnover45.
41 https://www.energystar.gov/sites/default/files/asset/document/ENERGY%20STAR%20Pool%20Pumps%20-
%20Program%20Requirements%20Version%201.1.pdf.
42 ENERGY STAR Certified Pool Pumps, available at: https://www.energystar.gov/products/certified-
products/detail/pool-pumps.
43 CASE Report, Pools & Spas (July 29, 2013), available at
http://www.energy.ca.gov/appliances/2013rulemaking/documents/proposals/12-AAER-
44 CASE Report, Analysis of Standards Proposal for Residential Swimming Pool & Portable Spa Equipment, available at
45 Stock turnover occurs when all pumps in California meet proposed standards.
18
CHAPTER 5: Alternative Consideration
Staff analyzed the proposal in the CASE report to determine whether it meets the legislative
criteria for the Energy Commission’s prescription of appliance efficiency standards. Staff also
reviewed and analyzed state standards for (1) maintaining current Title 20 standards, (2)
incorporating the CASE report suggestions, (3) incorporating the CASE team proposal with
tiered motor efficiency, and (4) incorporating the CASE team proposal with uniform full speed
efficiency for all motor types.
Alternative 1: Maintaining Current Title 20 Appliance

Standards
Staff believes the Title 20 standards need to be updated to adequately reflect the current
market. The standards rely on prescriptive definitions for pool pump and motor combinations
and replacement pool pump motors that result in low compliance rates. The standards should
set minimum motor efficiencies. Based on the increased market penetration of higher efficiency
products, it is reasonable to raise the minimum efficiency requirements to better reflect the
cost-effective savings these products offer.
Alternative 2: Incorporate CASE Team Proposal

The CASE team proposal would establish minimum motor efficiency requirements (full and half
speed) for all pump and motor combinations and replacement motors for residential and
commercial pools that are less than 5 hp. The recommended efficiency standards for single-
speed, dual-speed, and variable-/multiple-speed pump and motor combinations and
replacement pump motors are shown in Table 1, and would go into effect one year from
adoption. Most dual-speed motors in the Appliance Efficiency Database of certified pool pump
motors qualify with the proposed full-speed motor efficiencies while only some pass the half-
speed efficiency requirement. Figure 6 plots pump and motor combinations certified in the
database for both full- and half-speed motor efficiency.
The proposal recommends a half-speed requirement based on the half-speed horsepower of the
motor. Dual-speed half-speed motor minimum efficiencies would vary between 48 percent at 1
hp and 57 percent at 5 hp. Variable-speed half-speed motor minimum efficiencies would vary
between 63 percent at 1 hp and 72 percent at 5 hp. The proposal recommends a new CSA test
method C747-09 to verify motor efficiency. Implementation of these standards would result in
approximately 630 GWh of electricity savings once stock turnover is achieved in 2026
While the CASE team proposal offers significant energy savings, staff analysis suggests that
there are additional savings that can be achieved with a more stringent standard.
19
Table 1: IOU Proposed Standards for Pool Pump Motors - Effective July 1, 2017
Proposed Minimum Efficiency according to modified CSA C747‐09 Test Procedure
Motor Design Full Speed (3450 RPM) Half Speed (1725 RPM)
Single Speed (upto 1 HP) 0.06 ∗ ln 0.7 ∗ 100% N/A
Dual Speed 70% (0.06 ∗ ln 0.6 ∗ 100%
Variable Speed/Multi‐Speed 80% 0.06 ∗ ln 0.75 ∗ 100%
Figure 6: CASE Report Single-Speed Efficiency Standard
20
Figure 7: CASE Team Dual-Speed, Multi-speed, and Variable-Speed Efficiency Standard
Alternative 3: Incorporate CASE Team Proposal with Tiered

Motor Efficiency
In this alternative, proposed standards incorporate and expand upon the CASE team proposal
by establishing a two-tiered motor efficiency approach (see Table 2 and 3). The Tier 1 single-
speed motor efficiency is identical to the CASE Team proposal between 0.5 and 1 hp. Dual-
speed, multi-speed, and variable-speed motor efficiency will be set to a unified minimum motor
efficiency standard (see Table 2), effective one year from adoption. Tier 2 will be implemented
for dual-speed, multi-speed, and variable-speed four years after the adoption date and will raise
the unified minimum motor efficiency standard (see Table 2). Tier 1 will achieve 634 GWh of
electricity savings while Tier 2 will achieve an additional 78 GWh of electricity savings for a
combined 716 GWh savings between Tier 1 and Tier 2.
While Alternative 3 provides significant savings, Alternative 4 proposes more stringent

requirements for substantially more savings.
21
Table 2: Alternative 3, Tier I - Effective January 1, 2018
Proposed Minimum Efficiency according to modified CSA C747-09 Test Procedure
Single-Speed (up to 1 hp) (0.08*hp3450+0.62)*100% N/A
Variable-Speed/Multiple-
70% 50%
Speed/Dual-Speed (1 to 5 hp)
Table 3: Alternative 3, Tier II - Effective January 1, 2021

Single-Speed (up to 1 hp) (0.08*hp3450+0.62)*100% N/A
80% 65%
Alternative 4: Incorporate CASE Team Proposal with Uniform

Full Speed Efficiency for All Motor Types
In this alternative, staff proposed standards incorporate and expand upon the CASE team
proposal by establishing a two-tiered motor efficiency approach (see Table 4 and 5). While the
dual-speed and variable-speed efficiencies would remain the same as shown in Alternative 3,
the Tier 1 and Tier 2 single-speed motor efficiency would be set equal to the dual-speed, multi-
speed, and variable-speed motor efficiency at full speed. The Tier 1 and Tier 2 effective dates
would be the same as proposed in Alternative 3. Tier 1 will achieve 609 GWh of electricity
savings while Tier 2 will achieve an additional 569 GWh of electricity savings for a combined
1178 GWh savings. Staff believes the single-speed Tier 1 standard is technically feasible and
would request additional information on motors below 1 hp that can achieve a motor efficiency
of 80 percent or greater.
As discussed in the following section, staff believes that Alternative 4 is cost-effective,

technically feasible, and provides significant electrical energy savings.
Table 4: Staff Proposed Alternative 4, Tier I - Effective January 1, 2018

Motor Design Full-Speed (3450 RPM) Half-Speed (1725 RPM)
Single-Speed (up to 1 hp) 70% N/A
70% 50%
22
Table 5: Staff Proposed Alternative 4 Tier II Effective January 1, 2021.
80% 65%
Figure 8: Comparison of Single-Speed Motor Efficiency Alternatives
23
CHAPTER 6: Staff Proposed Standards for
Pool Pumps and Motor Combinations and
Replacement Pool Pump Motors
Energy Commission staff analyzed the cost-effectiveness and technical feasibility of standards
proposed in the CASE report, considered public comments, and surveyed the pool pump and
motor combination and replacement motor market. Based on the information available, staff
has determined that the savings resulting from reduced energy consumption under the
proposed standards are significant and cost-effective to consumers. In addition, staff
determined that the proposed standards are attainable through products available in the
market.
Scope
Staff proposes to expand the existing scope of pool pump and motor combinations and
replacement pool pump motors and to ensure that the standards can be enforced effectively.
Staff proposes to cover pool pump and motor combinations (pump and motor sold together)
and replacement pool pump motors (pumps sold alone) that are used for filtration and
circulation, to run water features and waterfalls, and as booster pumps. In addition, the
proposed scope will no longer distinguish between pool pumps used in residential pools and
small commercial pools. The regulation will continue to apply to pumps and motors serving
both in-ground and above-ground pools.
Staff amended the pool pump and motor definitions to expand the scope by removing
references to residential and filtration uses. New motor type definitions were added to
represent the current diversity of design solutions in the pool pump marketplace.
Motor Efficiency
Two tiers of standards are proposed for single-speed, dual-speed, multi-speed, and variable-
speed motors sold in combination with pool pumps or sold separately as replacements. These
proposed standards will take effect one and four years from adoption by the Energy
Commission, respectively.
Tier 1
All pool pump motors that are 5 hp or less, manufactured on or after January 1, 2018, shall
meet the efficiency standards outlined in Table 6.
24
Table 6: Tier I Proposed Standards for Pool Pump Motors
70% 50%
Figure 9: Tier 1 Single-Speed Motor Efficiency Standard
Staff proposes a simultaneous full-speed and half-speed minimum pool pump motor efficiency
for motors between 1 and 5 hp to impose minimum performance standards on the two primary
duty cycles for these motors. The minimum efficiencies are proposed to achieve significant
energy savings without imposing a significant burden on the pool pump motor industry, as
many products are available in the market that meet both the Tier 1 and Tier 2 standards.
25
Figure 10: Tier 1 Full Speed and Half Speed Motor Efficiency Standard
Tier 2
All pool pump motors that are 5 hp or less, manufactured on or after January 1, 2021, shall
meet the efficiency standards outlined in Table 7.
Table 7: Tier 2 Proposed Standards for Pool Pump Motors

Single-Speed (up to 1 hp ) 80% N/A
80% 65%
The proposed standards would result in significant electricity savings with the products
currently available on the market. The tiered efficiency requirements and effective dates
provide adequate time for industry to align manufacturing lines and product inventories to
meet consumer demand while providing a more efficient product.
26
Figure 11: Tier 2 Single-Speed Motor Efficiency Standard
27
Figure 12: Tier 2 Full-Speed and Half-Speed Motor Efficiency Standard
Remove Prohibition on Split-Phase and Capacitor-Start Induction Run Motors

Staff proposes to remove the prescriptive prohibition for split-phase and capacitor-start
induction run motor type, as the performance standard proposed in this staff report will
exceed the energy savings from the prescriptive requirements. The prohibited motor types have
full-speed efficiency in the range of 40 to50 percent, which is considerably lower than the
proposed full-speed efficiency standard46. Staff has removed the prohibition for split-phase
and capacitor-start induction run motor types because all motors must meet the efficiency
standard. The previously banned motor types could be sold in California under the new
proposed standard as long as they meet the minimum motor efficiency standard.
Based on its independent analysis of the available data, including that from the CASE report
and manufacturers’ information, staff concluded that the proposed regulations are both cost-
effective and technically feasible. Staff assumptions and calculation methods are provided in
Appendix A.
46 Davis Energy Group, Gary B. Fernstrom, Analysis of Standards Options for Residential Pool Pumps, Motors and
Controls, 2004, p. 6.
28
New Proposed Pool Pump Motor Types
Staff is aware of pool pump motor types in use that do not conform to the list of acceptable
types found in Title 20, Section 1606, Table X. Staff proposes to add motor types to allow
certification of all pool motor types capable of meeting the motor efficiency standard.
Motor Efficiency Test Procedure

Staff proposes to amend the current motor test procedure to require all pool motors to test to
the CSA 747-09, energy efficiency test methods for small motors.
The CSA 747-09 test method provides a better test method than the IEEE-114-2001. The CSA
test method is intended for all types of small motors while the IEEE method only includes
single-phase AC induction motors. The CSA test procedure allows for testing at multiple motor
speeds while the IEEE test procedure only allows for full-speed motor testing. The CSA 747-09
test procedure is superior because it has more expansive test conditions and motor types.
The proposed standard will require manufacturers to report performance data at up to four
speeds depending upon the speed capability of the pool pump motor. Single-speed motors will
report performance at full speed, while dual-speed motors will report performance at full and
half speed. Variable-speed motors and multi-speed motors will report performance at ¼, ½, ¾,
and full speed. The new reporting requirement will improve the consistency in reported
performance data by making the performance reported at uniform speeds. The reporting will
allow consumers, regulators, and industry to make more meaningful side-by-side comparisons
of motors at uniform speeds.
Pump Efficiency Test Procedure

The Appliance Efficiency Standard requires the pool pump for pool pump and motor
combinations to be tested to the Hydraulic Institute (HI) ANSI/HI 1.6-2001, Centrifugal Pump
Tests. Since the 2001 version, HI has updated and consolidated the test procedure for pumps to
ANSI/HI 14.6-2011, Rotodynamic Pumps for Hydraulic Performance Acceptance Tests. The
ANSI/HI-14.6-2011 incorporates the requirements for ANSI/HI 1.6. Staff seeks to update to the
ANSI/HI-14.6-2011 to the current test procedure used by the industry. The test procedure is
intended for factory testing of pump types used by the pool pump industry.
29
CHAPTER 7: Savings and Cost Analysis
The proposed standards would significantly reduce energy consumption. To determine

incremental cost of a pool pump motor that meets the proposal, the CASE team gathered retail
price data from pool pump and motor vendor websites. Staff performed an independent market
search and confirmed the retail price data in the CASE report. The data was analyzed to
estimate the cost difference to the consumer as motor efficiency increases. The CASE team
determined the cost increase estimate for motor size and motor type. Staff used the CASE team
analysis to estimate the incremental cost between non-compliant models and models that meet
but do not exceed the proposed standard. See Appendix A for a detailed calculation.
Table 8: Annual Energy and Monetary Savings per Unit

Product Design Electricity Incremental Avg. Life- Life-Cycle
Life Savings Cost ($) Annual Cycle Benefit ($)
(years) (kWh/yr) Saving Saving
s ($) s ($)
Variable-Speed Tier 1 10 0 $0 $0 $0 $0
Dual-Speed Tier 1 10 53 $5 $9 $85 $80
Dual-Speed Tier 2 10 352 $65 $56 $564 $499
Single-Speed Residential 10 297 $12 $48 $476 $464

Filtration Tier 1

Non-Filtration Tier 1
Single-Speed 10 682 $12 $109 $1,091 $1,079

Commercial Tier 1
Single-Speed Residential
Filtration Tier 2 10 186 $55 $30 $297 $242
Single-Speed Residential
Non-Filtration Tier 2 10 98 $55 $16 $157 $102
Single-Speed
Commercial Tier 2 10 2,335 $65 $374 $3,736 $3,671
Source: CASE report, as modified by staff
30
The values shown in Table 8 list the design life, incremental cost, and monetary savings in
2015 dollars, for each product. Thus, the average annual savings are the savings that
consumers will receive once the product is installed.
Note: estimation of cost and benefits is conservative as it does not consider utility rebates or
contractor discounted prices for installation (i.e., contractors purchase the pumps and install
them at a discounted price).
The annual savings of each unit (benefits) is calculated by multiplying the annual energy
savings by $0.16 per kWh47. The life-cycle benefit represents the savings the consumer will
receive over the life of the appliance and is the product of the average annual savings
multiplied by the average design life of the unit. The net life-cycle benefits are the differences
between the savings and the incremental cost of each appropriate unit.
Staff used the survey results from PG&E, SCE, and SDG&E, and as reported in the CASE report
for the total stock of pool pump motors by types. Approximately two million residential and
commercial pools are in use in California. Most employ single-speed motors48. Staff assumed a
1 percent growth rate for new pool installation based upon the Energy Commission energy
demand forecast and a conversation with the CASE team 49. Assuming a 10 percent
replacement rate based upon a ten-year design life, staff estimates yearly shipments of 200,000
units per year.
The savings estimates compare the baseline energy consumption for each product with their
respective energy consumption under the proposed standards. For statewide estimates, these
savings are multiplied by sales for first-year figures and by total California stock. The details of
these calculations are available in Appendix A. In Table 9, Table 10, and Table 11, the
potential energy savings of the proposed standards are provided. Energy savings are further
separated into first-year savings and stock savings. First-year savings means the annual
reduction of energy consumed associated with annual sales, one year after the standards take
effect. Annual stock savings means the annual energy savings achieved after all existing stock
in use comply with the proposed standards.
Staff calculations and assumptions used to estimate first-year savings and stock change savings
are provided in Appendix A. As provided in Table 9 and Table 10, staff estimated that if all
pool pumps and motors complied with the proposed Tier 1 and Tier 2 standards (annual stock
47 Energy Information Administration – electricity prices for 2013 through December 2013
http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_6_b.
49 Kavalec, Chris, Nicholas Fugate, Bryan Alcorn, Mark Ciminelli, Asish Gautam, Kate Sullivan, and Malachi Weng‑
Gutierrez, 2013. California Energy Demand 2014‑2024 Preliminary Forecast, Volume 1, California Energy Commission,
Publication Number CEC‑200‑2013‑004‑SD‑V1, p. 30.
31
savings), California would save 1178 GWh of energy per year. Using a residential electricity rate
of $0.16 per KWh, staff estimated that implementation of the proposed standards for pool
pumps and motors would achieve roughly $188 million a year in reduced utility costs after full
implementation.
Staff also calculated the peak power reduction to be 1178 GWh/8,760 hours, which is equal to
approximately 134 MW. This calculation is based on the simplified assumption that the load
profile for pool pumps and motors is completely flat and energy would be evenly generated
over the entire year to provide electricity to consumers.
Table 9: Tier 1 Statewide Annual Savings

First Year Savings Annual Existing and
Incremental Stock
Savings
Product Electricity Savings Electricity Savings

Savings ($M) Savings ($M)
(GWh/yr) (GWh/yr)
Variable-Speed 0.0 $0.0 0 $0.0
Dual-Speed 1.1 $0.2 11 $1.7
Single-Speed Residential Filtration 47.5 $7.6 475 $75.9
Single-Speed Residential Non- 8.8 $1.4 88 $14.0

Filtration
Single-Speed Commercial 3.6 $0.6 836 $5.7
Total Savings 60.9 $9.7 608.7 $97.4
Source: Staff Calculation
32
Table 10: Tier 2 Statewide Annual Savings
Incremental Stock
Savings

Savings Savings
($ million) ($ million)
(GWh/yr) (GWh/yr)
Variable-Speed Tier 2 1.0 $0.2 10 $1.6
Dual-Speed Tier 2 7.2 $1.2 72 $11.6
Single-Speed Residential Filtration

Tier 2 30.5 $4.9 305 $48.7
Single-Speed Residential Non-

Filtration Tier 2 5.6 $0.9 56 $9.0
Single-Speed Commercial Tier 2 12.6 $2.0 126 $20.2
Total Savings 56.9 $9.1 569.1 $91.0
Table 11: Tier 1 and Tier 2 Statewide Annual Savings

Product First Year Savings Annual Existing and
Incremental Stock
Savings
Electricity Savings Electricity Savings

Savings Savings
(GWh/yr) (GWh/yr)
Tier 1 Total Savings 60.9 $9.7 608.7 $97.4
Tier 2 Total Savings 56.9 $9.1 569.1 $91.0
Tier 1 and Tier 2 Total Savings 117.8 $18.8 1,177.8 $188.4

In conclusion, the proposed standards are clearly cost-effective as consumers will receive a net
savings from the installation of compliant pump and motor combinations and replacement
pool pump motors over the life of the pump.
33
CHAPTER 8: Pool Pumps and Motors Standard
Technical Feasibility
Motor Efficiency
Motor efficiency is the ratio of rotational power at the motor shaft to the electrical power input
to the motor. The motor efficiency will always be less than 100 percent due to losses within the
motor. Energy losses within electric motors are classified as conduction losses and speed
losses. Manufacturers have used a variety of approaches to achieve more efficient motor
performance.
Conduction Losses
Conduction losses are due to the resistance the electric current encounters when it flows
through a conductor; in this case, the winding wire inside the motor. The power is dissipated as
heat rather than converted into rotational energy. The power dissipated by electrical resistance
is proportional to the square of the applied current. Manufacturers have lowered the resistance
within the motor by modifying the stator and rotor geometry to add more area for the wire
conductors.50 Electrical losses predominate at low speed. Other sources of motor losses at low
speed such as friction are small compared to the conduction losses.
50 Machine Design, The difference between AC induction, permanent magnet, and servomotor technologies, available at
http://machinedesign.com/motorsdrives/difference-between-ac-induction-permanent-magnet-and-servomotor-
technologies.
34
Figure 13: Efficiency Improvements with Additional Rotor and Stator Conductors
Source: National Electrical Manufacturers Association
Speed Losses
Speed losses include hysteresis and eddy currents within the stator and rotor, frictional losses
within bearings, and motor windage (the loss the motor rotor encounters as a drag force as it
rotates through air)51. Hysteresis and eddy currents are due to the interaction between
alternating electrical currents and magnetic materials within both AC induction and ECM motor
stators and rotors. Losses can be reduced by minimizing stator and rotor steel laminations to
reduce eddy currents and using ferromagnetic materials with properties that present less
hysteresis. Bearing friction can be reduced by appropriate selection of bearings for the motor
load and speed. Motor windage can be reduced by streamlining airflow within the motor and
removing obstacles such as sharp edges or drastic changes in cross section52.
Stray losses are miscellaneous losses from leakage flux, non-uniform current distribution, and
mechanical imperfection in the air gaps between the rotor and windings stator. Careful design
and improved manufacturing processes can minimize stray losses and improve overall motor
efficiency.
51 Vrancik, James E., Prediction of Windage Power Loss in Alternators, NASA Technical Note D-4849, 1968, p. 4.
52 Tong, Wei, Mechanical Design of Electric Motors, CRC Press, 2014, p. 402.
35
Motor Efficiency Market Survey
Tables 12, 13, and 14 show existing pool pump motors compliant with Tier 1 and Tier 2 in the
Energy Commission database as of June 2015. The number of models that already comply
shows that the proposed efficiency standards are technically feasible for the pool pump motor
industry.
Table 12: Single-Speed Pool Pump Motor Performance

of Motors in Energy Commission Database - June 2015
Motor Size Total Tier 1 Tier 2
(hp) Models Compliant Compliant
0.5 3 2 0
0.75 1 1 0
1.0 20 11 0
Table 13: Dual-Speed Pool Pump Motor Performance in Energy Commission Database - June 2015
1 15 3 0
1.5 21 8 0
2 27 15 3
2.5 8 4 0
3 2 2 0
Table 14: Variable-Speed Pool Pump Motor Performance of

Motors in Energy Commission Database - June 2015
1 1 1 1
1.5 4 4 4
2 9 8 7
2.5 8 3 2
3 2 2 1
36
The Energy Commission database surveys show many models meeting the proposed motor
efficiency standards at the Tier 1 and Tier 2 levels. The quantity of pool pumps and motors
available for sale show compliant products are technically feasible. A significant market for
dual-speed or variable-speed motors less than 1 hp or greater than 3 hp was not found.
However, should such motors be needed, there do not appear to be any technical barriers to
prevent such motors from being compliant.
The Association of Pool & Spa Professionals (APSP) pool database53 shows two single-speed
pump models less than 1 hp that meet the 80 percent efficiency Tier 2 requirement and four
additional pump models above 79 percent efficiency. Staff believes the Tier 2 single-speed
efficiency requirement is obtainable with a modest improvement to the motor components.
Two or More Speed Pump Requirement

All new pumps and motors between 1 and 5 hp must be capable of operating at two or more
speeds. New pump and motor combinations, and replacement pool pumps between 1 and 5 hp,
shall all be dual-speed, multiple-speed, or variable-speed type. The requirement will extend to
all pool pumps and motors beyond the current requirement for residential filtration pumps
including motors for commercial pool pumps, booster pumps, and water effect pumps.
Pumps and motors under 1 hp total capacity may be single-speed in addition to dual-, multiple-,
or variable-speed.
The large quantity of pool pumps and motors available for sale (Table 13 and 14) from a
variety of manufacturers show compliant two or more speed products that are technically
feasible.
53 The Association of Pool and Spa Professionals (APSP) Energy Efficient Pool Pumps Database,
http://apsp.org/resources/energy-efficient-pool-pumps.aspx.
37
CHAPTER 9: Environmental Impacts
Impacts
Pool owners replace pool pumps and motors at the end of their useful lives. The proposed
standards would not change that, so their replacement would present no additional impact to
the environment beyond their natural cycle.
Benefits
Improving the efficiency of pool pumps and motors through mandatory appliance standards
will reduce overall energy consumption statewide, providing important air quality and climate
benefits. Staff estimated the reduction of criteria air pollutants54 and GHG emissions resulting
from the proposed standards. The reductions are tabulated in Table 15.
GHG emission reductions were calculated using the estimated avoided energy savings; it was
assumed that there are 690 lbs of avoided CO2e per MWh of electricity saved55. For criteria air
pollutants, the ARB suggested emission factors were used to estimate the cost-effectiveness of
emission reductions56:
 Oxides of nitrogen (NOx) = 0.07 lb per MWh,

 Sulfur dioxide (SOx) = 0.01 lb per MWh,
 Carbon monoxide (CO) = 0.1 lb per MWh,
 Particulate matters (PM2.5) = 0.03 lb per MWh.
54 Criteria air pollutants are those for which a state or federal standard has been established. They include nitrogen
dioxide (NO2), sulfur dioxide (SO2), carbon monoxide (CO), ozone (O3) and its precursors, oxides of nitrogen (NOx) and
volatile organic compounds (VOC), particulate matter less than 2.5 microns (PM2.5) and less than 10 microns in diameter
(PM10), and lead (Pb).
55 Energy Aware Planning Guide Feb 2011, available at
http://www.energy.ca.gov/2009publications/CEC-600-2009-013/CEC-600-2009-013.pdf.
56 ARB Economic Analysis Assumptions, available at http://www.arb.ca.gov/regact/2010/res2010/res10d.pdf.
38
Table 15: Criteria and Greenhouse Gas Emissions Reductions
Annual Reductions (tons) Avoided Emissions (tons)
Oxides of Sulfur Carbon Particulat Greenhouse

Nitrogen Dioxide Monoxide e Matter Gas (eCO2)
(NOx) (SOx) (CO) (PM2.5)
Dual- and Variable-Speed 0.37 0.05 0.53 0.16 3,670

Tier 1
Dual- and Variable-Speed 2.87 0.41 4.11 1.23 28,333

Tier 2
Single-Speed Tier 1 20.93 4.33 29.90 8.97 206,329
Single-Speed Tier 2 17.04 2.43 24.35 7.30 167,993
Total Avoided Emissions 41.22 7.23 58.89 17.67 406,324
As seen in Table 15, about 125 tons of criteria air contaminants and nearly 406 thousand tons
of GHG equivalents will be avoided annually due to the savings from the proposed standards.
39
CHAPTER 10: Regulatory Language
The following are the proposed changes to specific Sections of Title 20 applicable to pool
pumps and motors. Underline means new added text and strike out means deleted text.
Section 1601 Scope
…
(g) Gas pool heaters, oil pool heaters, electric resistance pool heaters, heat pump pool heaters,
residential pool pump and motor combinations, replacement residential pool pump motors,
and portable electric spas.
Section 1602(g) Pool Heaters, Portable Electric Spas, Residential Pool Pumps, and Motor
Combinations, and Replacement Residential Pool Pump Motors.
“Permanent Magnet Synchronous” means a motor that has a permanent magnet rotor and
windings on the stator controlled by single-phase sinusoidal alternating current.
“Polyphase induction” means an alternating current motor having polyphase (as three-phase)
windings.
“Reluctance” means a motor that generates torque through the use of non-permanent magnetic
poles and the reluctance phenomenon.
“Replacement residential pool pump motor” means a replacement motor intended to be

coupled to an existing residential pool pump that is used to circulate and filter pool water in
order to maintain clarity and sanitation.
“Residential pPool pump” means a mechanical device using suction or pressure to raise or
move non-potable water.an impeller attached to a motor that is used to circulate and filter pool
water in order to maintain clarity and sanitation.
“Residential pPool pump and motor combination” means a residential pool pump motor
coupled to a residential pool pump.
“Residential pPool pump motor” means a motor that is used as a replacement residential pool
pump motor or as part of a residential pool pump and motor combination.
“Shaded pole” means a motor that uses current flowing through a shading coil to delay the
phase of the magnetic flux to generate a rotating magnetic field.
“Total horsepower (of an AC motor)(of a pool pump motor)” means a value equal to the product
of the motorʹs service factor and the motorʹs nameplate (rated) horsepower.
40
Section 1604 (g) Pool Heaters, Portable Electric Spas, Residential Pool Pump and Motor
(3) The test method for residential pool pumps and motor combinations.
The test method for residential pool pumps and motor combinations is as follows
(A) Reported motor efficiency shall be verifiable by test method described in Section
1604 (g)(4)IEEE114‐2001.
(B) ANSI/HI 1.6‐2000 ANSI/HI 14.6‐2011 shall be used for the measurement of pump
efficiency.
(C) Three system curves shall be calculated.

…
(D) For each curve (A, B, or C), the pump head shall be adjusted until the flow and head
lie on the curve. The following shall be tested and reported (i) for each curve for
single‐speed pumps or (ii) for each curve at both highest and lowest speeds for
two‐,multi‐, or variable‐speed pumps for the intersect point of the pump
performance curve with each system curve:

1. Motor nominal speed
2. Flow (gallons per minute)
3. Power (watts and volt amps)
4. Energy Factor (gallons per watt hour)
Where the Energy Factor (EF) is calculated as:
EF = Flow (gpm)* 60/ power
5. Motor Efficiency (percent %)

(i) For single‐speed, two‐speed, or multi‐speed pumps with fixed, non‐adjustable
speeds, test and report performance at the intersect point of the pump performance
curve with each system curve (curves A, B, and C). Intersect data shall be reported
for each speed and system curve.
(ii) For two‐, multi‐, or variable‐speed pumps with adjustable speeds, test and report
performance at the intersect point of the pump performance curve with each system
curve (curves A, B, and C). Intersect data shall be reported for the speeds shown in
Table G‐3.

(4) Test Method for Pool Pump Motors

The test method for pool pump motors is as follows:

(A) Each pool pump motor shall be tested and in accordance with CSA‐C747‐09 with
modified torque settings at different speeds as is shown in Table G‐3 and G‐4.
41
(1) Single‐speed, two‐speed, multi‐speed, and variable‐speed pool pump motors shall
be tested at the speeds shown below in Table G‐3.

Table G-3 - Testing Criteria for Pool Pump Motors
Full Speed (34501 3/4 Speed (25901 1/2 Speed (17251 1/4 Speed (8601

Motor Design RPM) RPM) RPM) RPM)
Single‐Speed X N/A N/A N/A
Dual‐Speed X N/A X N/A
Variable‐
Speed X X X X
Multiple‐
Speed2 X X X X
1
Tolerance of +/‐50 RPM.
2
If no preset speeds exist within tolerance, then test to nearest preset speed.
(2) Torque settings and horsepower ratings for single-speed, two-speed, multi-speed, and
variable-speed pool pump motors shall be calculated as shown below in Table G-4.
Table G-4 - Torque Settings for Pool Pump Motors
Speed (RPMs) Torque Setting (N-m) Total Horsepower (THP)
RPMfull Full Speed (RPM) Tf (per section 6.5 of CSA THPfull

C747-09)
RPM3/4 Three Quarter Speed T3/4 = (RPM3/4 / RPMfull)2 x Tf THP3/4 = (RPM3/4 / RPMfull)3 x
(if applicable) (RPM) THPfull
RPM1/2 Half Speed (if T1/2 = (RPM1/2 / RPMfull)2 x Tf THP1/2 = (RPM1/2 / RPMfull)3 x
applicable) (RPM) THPfull
RPM1/4 One Quarter Speed T1/4 = (RPM1/4 / RPMfull)2 x Tf THP1/4 = (RPM1/4 / RPMfull)3 x
(if applicable) (RPM) THPfull
RPMx Other Preset Speed Tx = (RPMx / RPMfull)2 x Tf THPx = (RPMx / RPMfull)3 x THPfull
(if applicable) (RPM)
The torque T1 shall be set in accordance to CSA-C747-09.
...

The following documents are incorporated by reference in Section 1604.

42
…
CSA Group (CSA)

CSA C747‐09 Energy efficiency test methods for small motors

Copies available from: CSA Group
178 Rexdale Blvd
Toronto, ON
Canada M9W 1R3
http://shop.csa.ca/
Phone (416) 747 4044
FAX (416) 747 2510
…

HYDRAULIC INSTITUTE (HI))
…
ANSI/HI 1.6‐2000 Centrifugal Pump Tests

ANSI/HI 14.6‐2011 Standard for Rotodynamic Pumps for Hydraulic
Performance Acceptance Tests

Copies available from: Hydraulic Institute
9 Sylvan Way
6 Campus Drive
Parsippany, NJ 07054
http://www.pumps.org/
www.hydraulicinstitute.com
Phone: (973) 267‐9700
FAX: (973) 267‐9055

…
1605.1 (g) Pool Heaters, Portable Electric Spas, Residential Pool Pump and Motor
…
(6) Energy Efficiency Standards and Energy Design Standards for Residential Pool Pump and
Motor Combinations and Replacement Residential Pool Pump Motors. See Section 1605.3(g) for
energy efficiency standards and energy design standards for residential pool pump and motor
combinations and replacement residential pool pump motors.
…
1605.2 (g) Pool Heaters, Portable Electric Spas, Residential Pool Pump and Motor
43
…
(2) See Section 1605.3(g) for energy efficiency standards and energy design standards for
portable electric spas and residential pool pump and motor combinations and replacement
residential pool pump motors.
…
Section 1605.3 (g) (5) Residential Pool Pump and Motor Combinations, and Replacement
Residential Pool Pump Motors.
(A) Motor Efficiency.
1. Pool pump motors manufactured on or after January 1, 2006 may not be split-phase
or capacitor start – induction run type
2. 1. All pool pump motors that have a total horsepower of 5 hp or less, manufactured
on or after January 1, 2018, shall meet the efficiency standards in Table G-5.
Table G-5
Standards for Pool Pump Motors Manufactured on or After January 1, 2018
Minimum Efficiency Minimum Efficiency
Dual-Speed and Variable-

70% 50%
Speed/Multiple-Speed
3. 2. All pool pump motors that are 5 hp or less, manufactured on or after January 1,
2021, shall meet the efficiency standards in Table G‐6.

Table G-6 - Standards for Pool Pump Motors Manufactured on or After January 1, 2021
Minimum Efficiency Minimum Efficiency
Dual-Speed and Variable-

80% 65%
Speed/Multiple-Speed
(B) Two-, Multi-, or Variable-Speed Capability for Filtration Pool Pump Motors.
44
1. Residential Pool Pump Motors. Residential Ppool pump motors with a pool
pump motor capacity of 1 hp or greater which are manufactured on or after July
1, 2010, shall have the capability of operating at two or more speeds with a low
speed having a rotation rate that is no more than one-half of the motor's
maximum rotation rate. The pump motor must be operated with a pump control
that shall have the capability of operating the pump at least at two speeds.
Section 1606 Table X Continued - Data Submittal Requirements
Appliance Required Information Permissible Answers
PSC, Capacitor Start-Capacitor Run,

ECM, Capacitor Start-Induction Run,
G Residential Pool
Pool Pump Motor Construction Split-Phase, Permanent Magnet
Pump and Motor
Synchronous, Shaded Pole,
Combinations
Reluctance, Polyphase Induction
and
Replacement Single-speed, dual-speed, multi-
Pool Pump Motor Design
Residential Pool speed, variable-speed
Pump Motors
Frame
Maximum Speed (in RPM)
Motor has Capability of Operating at Two or

More Speeds with the Low Speed having a
Yes, no
Rotation Rate that is No More than One-Half
of the Motor’s Maximum Rotation Rate
Residential Pool Pump and Motor

Unit Type Combination, Replacement
Residential Pool Pump Motor
Pool Pump Motor Capacity
Motor Service Factor
Motor Efficiency at full speed (3450 RPM) (%)
Motor Efficiency at ¾ speed (2590 RPM) (%)

(multi-speed and variable-speed only)
45
Motor Efficiency at ½ speed (1725 RPM) (%)
(dual-speed, multi-speed and variable-speed
only)
Motor Efficiency at ¼ speed (860 RPM) (%)

(multi-speed and variable-speed only)
Nameplate Horsepower
Unit includes an integral pump controller. Yes, no
Pump Control Speed (compliance with

Yes, no
Section 1605.3(g)(5)(B)ii3.)
Flow for Curve ‘A’ (in

gpm)
Power for Curve ‘A’

(in watts)
Energy Factor for

Curve ‘A’ (in gallons
per watt-hour)
Flow for Curve ‘B’ (in

gpm)
This information Power for Curve ‘B’

must be reported for (in watts)
each tested speed, as
Energy Factor for
applicable (For pool
Curve ‘B’ (in gallons
pump and motor
per watt-hour)
combinations only).
Flow for Curve ‘C’ (in
gpm)
Power for Curve ‘C’

(in watts)
Energy Factor for

Curve ‘C’ (in gallons
per watt-hour)
46
1606(a) (4) Declaration
(v) all units of the appliance are marked as required by Section 1607, and, for the following
appliances, are marked as follows:
g. for residential pool pumps, each pool pump is marked permanently and legibly on an
accessible and conspicuous place on the unit, in characters no less than 1/4”, with the
nameplate HP of the pump and, if manufactured on or after January 1, 2010, with the
statement, “This pump must be installed with a two‐, multi‐, or variable‐speed pump motor
controller”;
h. for residential pool pump motors, each pool pump motor is marked permanently and legibly
on an accessible and conspicuous place on the unit, in characters no less than 1/4”, with the
pool pump motor capacity of the motor.
1607 (d) (9) Residential Pool Pumps.
(A) Each residential pool pump shall be marked, permanently and legibly on an accessible and
conspicuous place on the unit, in characters no less than 1/4”, the nameplate HP of the pump.
(B) Each residential pool pump motor shall be marked, permanently and legibly on an accessible
and conspicuous place on the unit, in characters no less than 1/4”, the pool pump motor
capacity of the motor.
(C) Two‐, multi‐, or variable‐speed residential pool pumps certified under Section 1606 of this
Article on or after January 1, 2010 shall be marked, permanently and legibly on an accessible
and conspicuous place on the unit, in characters no less than 1/4”,
47
APPENDIX A: Staff Assumptions and
Calculation Methods
Appendix A contains the information and calculations used to characterize pool pump and
motor combinations, and replacement pool pump motors in California, their current energy
use, and potential savings. The source of much of the information for these tables is the CASE
report submitted to the Energy Commission by the IOUs. All calculations were based on the
assumption of an effective date of January 1, 2017, although the effective date is January 1,
2018. The difference in effective dates does not significantly alter the calculations.
Stock and Sales

Table A-1 lists the annual sales of each appliance, the total stock of appliances for each
category, their duty cycle (annual hours of operation), and expected lifetime as surveyed by
PG&E, SCE, and SDG&E, and reported in the CASE report.
Table A-1: Stock and Sales

Product Total Stock Stock First -Year Total Stock First -Year Total Stock Lifetime
2012 Growth per Stock 2017 2017 Stock 2020 2020 (years)
(Thousand) Year (Thousand) (Thousand) (Thousand) (Thousand)
(Thousand)
Variable-Speed 180 2 19 189 19 194 10
Dual-Speed 190 2 20 200 21 205 10
Single-Speed Residential Filtration 1,520 15 160 1,596 164 1,642 10
Single-Speed Residential Non-Filtration 530 5 56 557 57 572 10
Single-Speed Commercial 50 1 5 53 5 54 10
Source: CASE report, p. 20 and staff calculation
Sales for 2017 and 2020 are estimated by dividing the total stock by the appliance lifetime in
years. Staff projected the 2017 and 2020 stock numbers by assuming a non-compounded
growth rate of 1 percent per year to the 2012 stock numbers presented in the CASE report. The
1 percent growth rate is based upon the California population forecast increase of about 1
percent57.
57 Kavalec, Chris, Nicholas Fugate, Bryan Alcorn, Mark Ciminelli, Asish Gautam, Kate Sullivan, and Malachi Weng‑
Gutierrez, 2013. California Energy Demand 2014‑2024 Preliminary Forecast, Volume 1, California Energy Commission,
Publication Number CEC‑200‑2013‑004‑SD‑V1, p. 30.
48
Residential and commercial pool pumps and motors are separated for energy consumption
calculations due to different duty cycles.
Example: Variable-speed pumps total stock and sales calculation:
Total Stock 2017

N2017 = N2012 × 1.05%
189,000 = 180,000 × 1.05%
Sales 2017
S2017 = N2017 ÷ L
18,900 = 189,000 ÷ 10
where:
S2017 = Sales for year 2017
N2017 = Total stock for year 2017
L = Product lifetime in years
Compliance Rates
Staff used the CASE report estimates for compliance to the proposed motor efficiency
standards. The single-speed, dual-speed, and variable-speed Tier 1 and Tier 2 compliance rates
were estimated based upon data in the Energy Commission’s Appliance Efficiency Database and
the CASE report. Table A-2 lists current compliance rates for the proposed standards.
Table A-2: Compliance Rates

Product Non- Compliance Compliance
Compliant Tier 1 (%) Tier 2 (%)
(%)
Variable-Speed 0 100 90
Dual-Speed 80 20 5
Single-Speed Residential Filtration 80 20 5
Single-Speed Residential Non- 80 20 5

Filtration
Single-Speed Commercial 80 20 5
Source: CASE report, p. 22, and Energy Commission Appliance database
Duty Cycle
The duty cycle is an estimate of consumer behavior for pool pump motor combinations and
replacement pool pump motors. Duty cycle describes how often and for how long the product
is used. The duty cycles represent current average annual usage to make meaningful estimates
49
of product energy consumption and savings. These figures rely on metering and behavior
studies where possible, and use reasonable estimates where this type of information is
unavailable.
Table A-3: Duty Cycle

Product Full Speed Half
(hrs/yr) Speed
(hrs/yr)
Variable-Speed 700 1800
Dual-Speed 700 1800
Single-Speed Residential Filtration 1700 N/A
Single-Speed Residential Non- 900 N/A

Filtration
Single-Speed Commercial 8760 N/A
Source: CASE report
Baseline Energy Use

The power consumption assumptions for pool pump and motor combinations, and replacement
pool pump motors are derived from the CASE report, which relies on market data gathered by
utilities and pool owner surveys to determine full-speed and half-speed usage. The baseline
usage was calculated for single-speed, dual-speed, and variable-speed at various motor sizes.
Baseline motor efficiency was estimated by calculating the average efficiency of non-compliant
models in the Energy Commission’s Appliance Efficiency Database. Estimated annual energy
consumption per pool pump type and size is calculated using a combination of the power of
the various modes and the duty cycles of those modes. For example, the annual energy
consumption of full speed is calculated by multiplying full-speed mode power by full-speed
mode duty cycle. For each motor type, the average energy consumption was calculated and is
shown in Table A-4 and A-5. The average was weighted based upon sales data per motor size.
The average annual energy consumption for a given product was calculated as follows:
The power consumption calculation is performed for both the full-speed and half-speed mode
of operation with values for name plate power, motor service factor, and efficiency for full and
half speed gathered from the CASE report and the Appliance Efficiency Database. Compliance
rates are assumed to be same for both full and half speed since the motor must meet both
standards.
Total motor power output capacity

Po = Pnp × SF
where
Po = Total motor power output capacity
50
Pnp = Nameplate motor output
SF = Service Factor
For example total motor capacity of a 1 hp motor with 1.25 service factor is:
Po = 1 hp x 1.25 = 1.25 hp
The half speed total motor capacity is found by observing the pump affinity laws.
Phalf speed = Pfull speed × (1/2)3
where
½ represents the ratio of half speed to full speed
Convert hp to kilowatts (kW) using conversion factor.
kW= .746 (kW/hp)× hp
Full speed baseline power consumption:

Pi = (Po ÷ η non compliant) × (1-C) + (Po ÷ η compliant) × (C)
where:
Pi = Motor power input at full speed
Po = Motor power output at full speed
C = Compliance rate
η non compliant =Average motor efficiency at full speed for non-compliant units
η compliant =Average motor efficiency at full speed for compliant units
Half speed baseline power consumption:

Pi = (Po ÷ η non compliant) × (1-C) + (Po ÷ η compliant) × (C)
where:
Pi = Motor power input at half speed
Po = Motor power output at half speed
C = Compliance rate
η non compliant =Average motor efficiency at half speed for non-compliant units
η compliant =Average motor efficiency at half speed for compliant units
Average full speed power

Pannual average = (P1.0 hp × %1.0 hp) + (P1.5 hp × %1.5 hp) + (P2.0 hp × %2.0 hp)+ (P2.5 hp × %2.5 hp) + (P3 hp × %3 hp )
where:
Pannual average = Average full speed power per appliance type
P1.0 hp = Full speed input power as calculated above for 1.0 hp motor
%1.0 hp = percent sales at 1.0 hp

51
Average half-speed power per appliance is calculated in a similar manner.
Average Energy consumption per appliance per motor size:
Eannual = (Pavg full speed × Dfull speed) + (Pavg half speed × Dhalf speed)
where:
Eannual = Annual energy consumption per appliance
Pavg full speed = Power input calculated above for full-speed motor operation
Pavg half speed = Power input calculated above for half-speed motor operation
Dfull speed = Duty cycle for full speed
Dhalf speed = Duty cycle for half speed
Total stock energy consumption per motor type:
Etotal baseline stock = Eannual baseline × N2017

where:
Etotal stock = Total baseline stock energy consumption per motor type
Eannual average = Average annual energy consumption per appliance type
Table A-4 presents baseline energy consumption prior to the Tier 1 motor efficiency standard.
Table A-5 presents the baseline energy consumption assuming 100 percent compliance with
Tier 1 to show the effect of the Tier 2 regulation.
Table A-4: Tier 1 Baseline Energy Consumption

Product Full Speed Half Annual Total
(kW) Speed Energy Annual
(kW) Consumption Stock
(kWh per Energy
Appliance Use
/yr) (GWh/yr)
Variable-Speed Tier 1 3.16 0.55 3,209 606
Dual-Speed Tier 1 2.34 0.43 2,403 479
Single-Speed Residential Filtration 1.09 N/A 1,860 2,969
Single-Speed Residential Non- 1.09 N/A 985 548

Filtration
Single-Speed Commercial 2.32 N/A 20,345 1,068
52
Table A-5: Tier 2 Baseline Energy Consumption

(kWh per Energy
Appliance Use
/yr) (GWh/yr)
Dual-Speed Tier 2 2.30 0.40 2,331 478

Filtration
53
Table A-6: Sales Weight Data
Product Class Nameplate Motor Power (hp) Sales Weight by hp (%)
Variable‐Speed 1 13
1.5 10
2 16
2.7 19
3 42
Dual‐Speed 0.75 9
1 29
1.5 28
2 4
2.5 4
3 26
Single‐Speed Filtration 0.5 12
0.75 84
Single‐Speed Non‐Filtration 0.5 12
0.75 84
Single‐Speed Commercial 1 30
1.5 32
2 20
2.5 7
3 11
Source: CASE report (shown in spreadsheet but not in text of CASE report)
54
Table A-7: Tier 1 Efficiency and Compliance Data
Product Nameplate Full‐Speed Half‐Speed Tier 1 Full‐ Tier 1 Half
Class Motor Motor Motor Speed Motor speed Motor
Power (hp) Efficiency Efficiency Efficiency Efficiency
(non‐ (non‐ (compliant (compliant
compliant compliant units) units)
units) units)
Variable‐ 1 0.70 0.50 0.70 0.50
Speed
1.5 0.70 0.50 0.70 0.50
2 0.70 0.50 0.70 0.50
2.7 0.70 0.50 0.70 0.50
3 0.70 0.50 0.70 0.50
Dual‐Speed 0.75 0.68 0.38 0.70 0.50
1 0.66 0.41 0.70 0.50
1.5 0.7 0.47 0.70 0.50
2 0.7 0.49 0.70 0.50
2.5 0.7 0.50 0.70 0.50
3 0.7 0.50 0.70 0.50
Single‐ 0.5 0.61 N/A 0.70 N/A
Speed
0.75 0.56 N/A 0.70 N/A
Filtration
Single‐ 0.5 0.61 N/A 0.70 N/A
Speed Non‐
0.75 0.56 N/A 0.70 N/A
Filtration
Single‐ 1 0.66 N/A 0.70 N/A
Speed
1.5 0.65 N/A 0.70 N/A
Commercial
2 0.67 N/A 0.70 N/A
2.5 0.70 N/A 0.70 N/A
3 0.70 N/A 0.70 N/A
Source: CASE report
55
Table A-8: Tier 2 Efficiency and Compliance Data
Product Nameplate Full‐Speed Half‐Speed Tier 2 Full‐ Tier 2 Half‐
Class Motor Motor Motor Speed Motor Speed Motor
Power (hp) Efficiency Efficiency Efficiency Efficiency
(non‐ (non‐ (compliant (compliant
compliant compliant units) units)
units) units)
Variable‐ 1 0.7 0.50 0.8 0.65
Speed
1.5 0.7 0.50 0.8 0.65
2 0.7 0.50 0.8 0.65
2.7 0.7 0.50 0.8 0.65
3 0.7 0.50 0.8 0.65
Dual‐Speed 0.75 0.7 0.50 0.8 0.65
1 0.7 0.50 0.8 0.65
1.5 0.7 0.50 0.8 0.65
2 0.7 0.50 0.8 0.65
2.5 0.7 0.50 0.8 0.65
3 0.7 0.50 0.8 0.65
Single‐ 0.5 0.7 N/A 0.8 N/A
Speed
0.75 0.7 N/A 0.8 N/A
Filtration
Single‐speed 0.5 0.7 N/A 0.8 N/A
non‐
0.75 0.7 N/A 0.8 N/A
filtration
Single‐ 1 0.7 N/A 0.8 N/A
Speed
1.5 0.7 N/A 0.8 N/A
Commercial
2 0.7 N/A 0.8 N/A
2.5 0.7 N/A 0.8 N/A
3 0.7 N/A 0.8 N/A
Source: CASE report
56
Compliant Energy Use
The power consumption of compliant products is estimated based on minimum requirements
to meet the proposed regulations. For example, the proposed full-speed motor efficiency is 70
percent, so products were assumed to consume exactly the bare minimum power to accomplish
this standard. It is noted those cases where the baseline power for a given mode was already
less than the standard that the report does not assume that power will increase, but rather that
it will remain the same. The annual energy consumption is calculated using the same
methodology as baseline energy use. Table A-6 and A-7 show predicted energy consumption of
compliant units and stock.
Table A-9: Tier 1 Compliant Energy Consumption

(kWh per Energy
Appliance Use
/yr) (GWh/yr)
Variable-Speed 3.16 0.55 3,209 606
Dual-Speed 2.31 0.41 2,349 469

Filtration
57
Table A-10: Tier 2 Compliant Energy Consumption
(kWh per Energy
Appliance) Use
Dual-Speed Tier 2 2.03 0.31 1,979 406

Filtration
Single-Speed Commercial 1.96 N/A 17,205 929
Cost and Energy Savings

The annual existing and incremental stock energy savings are calculated by subtracting the
compliant energy use from the baseline energy use.
Stock Energy Savings

Estock savings = Ebaseline stock- Ecompliant stock
where:
Estock savings = Annual stock energy savings at full stock turnover
Ebaseline stock = Annual stock baseline energy consumption
Ecompliant stock = Annual stock compliant energy consumption
First Year Energy Savings

E 1 year savings = Estock savings ÷ L
where:
E 1 year savings = Energy savings from first years sales of compliant units.
Estock savings = Annual stock energy savings at full stock turnover
58
Table A-11: Tier 1 Statewide Cost and Energy Savings
Incremental Stock
Savings

Savings Savings
(GWh/yr) (GWh/yr)
Variable-Speed 0.0 $0.0 0 $0.0
Dual-Speed 1.1 $0.2 11 $1.7

Filtration
Total Savings 61.0 $9.8 610 $97.6
Table A-12: Tier 2 Statewide Cost and Energy Savings

Incremental Stock
Savings

Savings Savings
(GWh/yr) (GWh/yr)
Variable-Speed Tier 2 1.0 $0.2 10 $1.6
Dual-Speed Tier 2 7.2 $1.2 72 $11.5

Filtration
Total Savings 56.9 $9.1 569 $91.1
59
Table A-13: Tier 1 and Tier 2 Statewide Cost and Energy Savings
Incremental Stock
Savings
Electricity Savings Electricity Savings

Savings Savings
(GWh/yr) (GWh/yr)
Tier 1 Total Savings 61.0 $9.8 610 $97.6
Tier 2 Total Savings 56.9 $9.1 569 $91.1
Tier 1 and Tier 2 Total Savings 117.9 $18.9 1179 $188.7
Unit cost savings (benefits) are calculated by multiplying the annual energy savings by $0.16
per kWh and by the design life.
Annual Unit Energy Savings

Eannual savings = Eannual baseline – Eannual Compliant
where:
Eannual savings = Annual unit energy savings
Eannual baseline = Annual unit baseline energy consumption
Eannual compliant = Annual unit compliant energy consumption
Lifetime Unit Energy Savings

Benergy savings = Eannual savings × L
where:
Benergy savings = Lifetime unit energy savings
Eannual savings = Annual unit energy savings
Net unit savings are calculated by subtracting costs from benefits.
Net energy savings:

Bnet = Benergy savings – Cincremental
where:
Bnet = Net energy savings
Benergy savings = Lifetime unit energy savings
Cincremental = Incremental cost
60
Table A-14: Annual Energy and Monetary Savings
Product Design Electricity Incremental Average Life Life-
Life Savings Cost ($) Annual Cycle Cycle
(years) (kWh/yr) Savings Savings Benefit
($) ($) ($)
Dual-Speed Tier 1 10 53 $5 $9 $85 $80
Dual-Speed Tier 2 10 352 $65 $56 $561 $496

Filtration Tier 1

Single-Speed Commercial 10 682 $12 $109 $1,091 $1,079

Tier 1

Filtration Tier 2

Single-Speed Commercial 10 2,335 $65 $374 $3,736 $3,671

Tier 2
61
PART B: PORTABLE ELECTRIC SPAS
62
Chapter 11: Product Description
Portable electric spas are factory-built, free-standing electric spas or hot tub units that are
either rigid or inflatable in design. They are defined as above-ground units that are electrically
heated and not permanently installed in the ground and/or attached to a pool. They are
supplied with pumps, heaters, and jets for heating, circulating, filtering, and maintenance, all of
which result in a significant energy consumption statewide.
According to a 2013 APSP market report, over 1 million spas are being used in California and
over 100,000 new units were sold each year in 2011 and 201258. Uses vary from recreational to
health and fitness use. There are various comfort features and configurations of the heating
system, the pumping system, and the filtering system for portable electric spas, making them
one of the highest residential electrical loads59. The typical components in portable electric
spas include: a heating element, a pump and motor combination, a filter, insulation, a shell or
tub wall, an exterior cabinet, jets, and, optionally, a spa cover (see Figure 1460). These
components provide opportunities for energy efficiency improvements. The average lifetime of
a portable electric spa is 10 years; a spa cover has an average lifetime of 5 years61.
58 The Association of Pool & Spa Professionals, P.K. Data Research Industry Statistics. Retrieved from
http://apsp.org/portals/0/images/APSP%20statistics%202013.jpg.
59 Davis Energy Group, Energy Solutions, (2004), Analysis of Standards Options for Portable Electric Spas. California:
PG&E.
60 Hamill, A. I. (2012). Measurement and Analysis of the Standby Power of Twenty-Seven Portable Electric Spas.
California Polytechnic State University, San Luis Obispo, Mechanical Engineering . San Luis Obispo: Andrew Ian Hamill.
61 Worth, C., & Fernstrom, G. (2014). Codes and Standards Enhancement (CASE) Initiative for PY 2012: Title 20
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, PG & E. California
Statewide Utility Codes and Standards Program. Retrieved July 2015.
63
Figure 14: Typical Components in a Portable Electric Spa.
Source: The Spa Guys, How Hot Tubs Work
As of July 2015, the Energy Commission’s modernized appliance efficiency database system
(MAEDBS) lists 1,180 certified portable electric spas. There are currently spas that are
distinguished as hot tubs/portable spas and exercise spas/swim spas. For this report, two types
of spas were analyzed: portable spas and exercise spas. Using the certified portable electric spa
manufacturers in the MAEDBS as sources, the overall key differences between the two types of
spas are the volume capacity (or water surface area), the type of features, and the intended use.
Portable Spas
Portable spas are mostly intended for recreational use and provide the user with a comforting
warm-water massage by electrically heating and aerating the water62. Portable spas may include
hydrotherapy or therapeutic features which use a jet system that projects streams of water at
different pressure outputs in multiple locations. The volume capacity for portable spas can
range from 120 gallons to more than 800 gallons63. Portable spas may be rigid bodied or
inflatable, and typically have a temperature range between 60°F and 104°F64.
Exercise Spas
Exercise spas are intended for health, fitness, and recreational use. Health and fitness uses
include swimming, aquatic fitness or exercising, and hydrotherapy. The swimming mode uses a
propulsion system to create a current of rushing water the user can swim against. The
62 Jacuzzi. (2011, November 30). Jacuzzi Hot Tubs Lists the Most-Wanted Hot Tub Feature. Retrieved from Jacuzzi:
http://www.jacuzzi.com/hot-tubs/about/press-releases/jacuzzi-hot-tubs-lists-most-wanted-hot-tub-feature/.
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, PG&E. California
64 CEC certified portable electric spa manufacturers: Catalina Spas, Masters Spas Inc., Sundance , Dimension One Spas.
64
therapeutic mode offers hydrotherapy configurations for exercising or for physical therapy,
thus requiring a larger volume or water surface area65. Exercise spas are designed to have two
separate bodies of water at different temperatures called combination spas, one for swimming
and the other for hydrotherapy66. USA Swimming and the Aquatic Exercise Association
recommend a water temperature range of 78°F to 82°F for competitive swimming, 83°F to 88°F
for aquatic exercise, and 90°F to 95°F for aquatic therapy. Most exercise spas have a built-in
temperature range of 60°F to 104°F67 and are capable of meeting those recommendations. The
user can still select the temperature of their choice. Exercise spas have capacities that range
from 900 gallons to 2,500 gallons68.
Using the volume ranges stated above for the two types of portable electric spas and the
MAEDBS, there are 33 certified exercise spas ranging from 1,058 gallons to 2,355 gallons and
29 of the these spas are designated as exercise/swim spas by the manufacturer69. For portable
spas, there are 1,148 certified portable spas ranging from 117 to 850 gallons.
Heating System
Portable electric spas heat water electrically. The heating system accounts for the majority of
the energy consumption. Most heating systems use electric resistance heaters and in some
cases waste heat from the pump system to heat and maintain the water at a set temperature70.
According to a 2012 Cal Poly study, the heater is used during startup, standby, and active use.
During startup mode, the recently filled water is heated to a set temperature or temperature
range with the spa cover on. The startup mode can take from 5 to over 24 hours to reach a
water temperature of 102°F. After the water has reached the set temperature, the unit is put
into standby mode to maintain the set temperature, and to circulate and filter the water. When
it is time for use, the spa cover is removed, and the spa is occupied. The heater is used to
maintain the set temperature71. Most spas are kept in standby mode year round72 when not in
use, since startup mode requires a lot of time and energy. Over the lifetime of the unit, the
65 Hartey, M. (2013). Swim Spa Basics. Retrieved from Pool & Spa Outdoor: http://www.poolspaoutdoor.com/hot-tubs-
swim-spas/swim-spas/articles/swim-spa-basics.aspx.
66 Poolandspa.com. (2015, August 21). What is a swim spa? Retrieved from poolandspa.com:
http://www.poolandspa.com/page6210.htm.
67 CEC certified portable electric spa manufacturers: Catalina Spas, Masters Spas Inc., Sundance , Dimension One Spas
68 Various exercise spa manufacturers: Artic Spas, Dimension One Spas, and Master Spas Inc.
69 Exercise/Swim Manufacturers: Master Spas Inc., Dimension One Spas, Blue Falls Manufacturing, Spa Manufacture
Inc., Catalina Spas, Marquis Corp., L.A. Spas Inc.
70 Davis Energy Group, Energy Solutions. (2004). Analysis of Standards Options for Portable Electric Spas. California:
PG&E.
65
standby mode represents typically 75 percent of the energy consumed by a portable electric
spa73. Over half of the energy consumed during standby mode is due to maintaining heat74.
The heating system functions the same through each mode. There are many configurations of
the heating system, but generally the pump draws water from the footwell through a suction
fitting and/or from the surface through a skimmer/filter to the heater. A general configuration
is shown in Figure 15. The warm water is returned to the spa through the jets or a main return.
The water can be filtered before or after reaching the heater.
Figure 15: Heating and Pumping System
General configuration of the heating system and pumping system in a portable electric spa.
Source: Spa Plumbing Diagrams, PoolSpasHelp.com
Electric resistance heaters are theoretically 100 percent energy efficient since all the electricity
is converted to heat75. Resistance heaters in portable electric spas can have efficiencies of 98
percent or more76. Thus, the energy efficiency is already high for heaters in a portable electric
spa.
73 Appliance Standards Awareness Project. (2015). Portable Electric Spas. Retrieved from ASAP - Appliance Standards
Awareness Project: http://www.appliance-standards.org/product/portable-electric-spas.
PG&E.
75 U.S. DOE. (2015). Electric Resistance Heating. Retrieved from Energy.gov:
http://energy.gov/energysaver/articles/electric-resistance-heating.
PG&E.
66
Pumping System
After the heating system, the pumping system is the most energy-intensive integrated part of a
portable electric spa, and can account for 25 to 50 percent of the total energy consumed by the
unit depending on how often different features are used. The energy consumption can vary
since there are many possible configurations for the pumping system. Most portable electric
spas have at least one pump with multiple speed options for filtering, circulating, aerating, and
jet action. For example, some spas have a two-speed pump motor where the low-speed option is
used during standby mode and the high-speed option is used for operating the jets. These
pumps are not very efficient in any mode, especially during standby because the motor is
lightly loaded and running at low efficiency77. Some models include a separate pump for
specific features and/or maintenance duties which can save a significant amount of energy over
the low-speed option on a larger pump78. Larger spas, like exercise spas, typically have
multiple pumps. For example, exercise spas sold in California can have up to four pumps79.
Depending on how the unit is setup internally, the pumping system functions nearly the same
for the heating process and the filtering process. Water is pumped into the heating element
and/or the filter, the water is then returned to the unit through the jets or a main return. For
other maintenance duties and features, such as aeration, circulation, and hydrotherapy, the
pumping system supplies water and air to the jets at varying pressures80. The type of jets
within a system can vary as well, some supply air and water separately, but most are a
combination of air and water (see Figure 16.) Portable electric spas that are marketed as
hydrotherapy spas have multiple jets of different types. Increasing the number of jets increases
the power demand of the pumping system. Thus, some units include a separate pump for jets
and/or circulation81. The secondary pump can be used to optimize the primary pump and
generate savings in standby mode.
77 Western Area Power Administration. (2009). What goes into an Energy-Efficient Spa or Hot Tub? Lakewood: Western
Area Power Administration.
79 Masters Inc. (2014). Models - H2X Swim Spas. Retrieved July 2015, from H2X Water To The Extreme, available
athttp://www.h2xswimspa.com/h2x-swimspa-models.html.
67
Figure 16: Standard Jet Cross-Section
Source: H2X Swim Spas, Master Inc.
Water Treatment
The water treatment system is inclusive of the pumping system since water treatment requires
circulation and suctioning of water through the filtration unit. Filtration cycles can vary from
programmed settings to an all-year round continuous setting. Portable electric spas typically
have one central pump that performs all operations including the filtration cycle, although
some spas use a separate pump specifically for filtration and circulation82. Again, the filtration
system can have various configurations and can include different types of water treatment
mechanisms to improve water quality, such as cartridge filters with or without media,
skimmers, an ozonator, UV system, and the addition of minerals and sanitizing chemicals83. A
single cartridge filter is the most common filtration system for smaller spas. Larger spas
typically have a cartridge filter and an ozone treatment system paired together (see Figure 17.)
Untreated water is suctioned through the cartridge filter, where large particles and
contaminants are removed84. For units that include an ozonator (an ozone system), the filtered
water is injected and mixed with ozone (O3) an oxidizing-agent that effectively treats organic
Statewide Utility Codes and Standards Program. Retrieved July 2015
83 The Spa Depot. (2015). Hot Tub Maintenance. Retrieved from SpaDepot.com:
http://www.spadepot.com/spacyclopedia/hot-tub-maintenance.htm.
84 National Academy of Sciences. (2007). Filtration Systems - Technologies. Retrieved from Safe Drinking Water is
Essential: http://www.koshland-science-museum.org/water/html/en/Treatment/Filtration-Systems-
technologies.html#tech4.
68
and inorganic contaminants. The treated water is then returned to the water through the jets or
a main return85.
Figure 17: Water Treatment System in a Portable Electric Spa
A typical water treatment system which includes a cartridge filter and an ozonator.
Source: Baja Spas
Insulation and Spa Covers

Since portable electric spas circulate and heat water, reducing the energy consumption of the
heating system presents an opportunity to save energy. To this end, manufacturers use good
insulation and spa covers to combat heat and water loss. Insulation minimizes heat loss during
operating and idle periods, while a spa cover minimizes heat loss and water loss through
evaporation. Ensuring that a spa cover is being used, and improving the cover and insulation
reduces the work of the heater and the pump motor needed to maintain a set temperature
during idle periods.
The spa unit insulation and spa cover offer the greatest opportunity to save energy, since they
help retain the heat in the water by their design and construction materials. Insulation is used
within the walls of the spa unit and within the spa cover. The insulation used within the walls
or the cavity between the tub wall and the cabinet enclosure is usually either foam or fiberglass.
According to the Energy Commission database, over 99 percent of spas listed are fully
insulated86.
85 National Academy of Sciences . (2007). Chemical Disinfection/Oxidants - Technologies. Retrieved from Safe Drinking
Water is Essential: http://www.koshland-science-museum.org/water/html/en/Treatment/Chemical-Disinfection-
Oxidants-technologies.html#tech3.
86 California Energy Commission. (2015). MAEDBS. Retrieved from Appliance Search
http://maedbs/Pages/ApplianceSearch.aspx.
69
For spa covers, according to the 2009 Residential Appliance Saturation Survey, 43 percent of
California spa owners did not own a spa cover87. Not all portable electric spas are sold with a
spa cover. Consumers need to be made aware that a spa cover is a key component to their
system. Using a spa cover is critical to saving energy and water (lost through evaporation.) The
evaporation rate due to not using a spa cover while heating the water from 60°F to 102°F was
calculated by using the average volume capacity in each volumetric zone to determine a typical
water surface area for that volume (see Table 16.). Larger units typically have a greater water
surface area which results in more water and heat loss than standard units. For example, a 450
gallon unit can lose more than one gallon of water per hour, whereas a 2,250 gallon can lose
almost three gallons of water per hour. Looking at the evaporation rate as a relationship
between the exposed surface area of water relative to the volume of the unit will separate the
spas into different groups or “zones” that better represent the water losses that occur.
Table 16: Evaporation Rate Without a Spa Cover
Unit Volume Water Evaporation

Zone Capacity Surface Rate, wp
(gallons) Area (m2) (gallons/hr)
Zone 1A 140 3.3 0.70

Zone 1B 240 3.9 0.83
Zone 2 450 5.7 1.21
Zone 3 750 5.8 1.23
Zone 4 1,050 8.0 1.69
Zone 5 1,350 8.7 1.85
Zone 6 1,650 10.9 2.31
Zone 7 1,950 13.0 2.76
Zone 8 2,250 14.0 2.96
The evaporation rate (wp) due to not using a spa cover by water
surface area relative to volume capacity.
Source: Design Considerations for Pools and Spas (Natatoriums) by John

W. Lund, see Appendix B for calculations.
Assuming evaporation rates of 0.5 gallons to 2.96 gallons during standby operating hours
(8,760 hours per year), as shown in Table 2, a determination can be made about the amount of
energy required in a worst case scenario to heat the spa, the evaporation rate, the water wasted,
and the costs associated with not using a spa cover. The energy costs range from $1,800 to
$10,500 per unit per year. The amount of water that evaporates due to not using a spa cover is
87 KEMA. (2010). California Statewide Residential Appliance Saturation Study. Retrieved from
https://websafe.kemainc.com/RASS2009/Default.aspx.
70
significant as well. For an evaporation rate of one gallon of water per hour, the amount of water
wasted is about 8,700 gallons per year per unit (see Table 17.) Using a cover can reduce
evaporation by 90 to 95 percent88.
Table 17: Annual Energy and Water Waste Without a Spa Cover
Energy
Costs
Evaporation Energy Water Lost to
for
Rate, wp Consumption Evaporation
Heating
(gallons/hr) (kWh/year) (gallons/year)
Water
($)
0.5 10,844 4,380 $1,756
1 21,688 8,760 $3,511
2 43,376 17,520 $7,023
3 65,064 26,280 $10,534
Source: Building Technology: Mechanical and Electrical Systems by B. Stein
See Appendix B for calculations.
Spa covers conserve heat by reducing heat flow due to conduction, convection, radiation, and
evaporation. The foam core within the spa cover acts as a thermal insulator, reducing heat
transfer from the warm water to the colder air outside (see Figure 1889) The insulating
material’s thermal resistance, in this case the foam core, is measured or rated by the R-value,
which depends on the insulation type, thickness, and density. A high R-value indicates greater
resistance to heat flow90.
Figure 18: Cross-Section of a Spa Cover
A cross-section of a typical spa cover. The arrows indicate heat loss disspating through
the foam core.
Source: Duratherm, The Spa Depot
88 Azusa Light & Water. (2015, July 27). Rebates. Retrieved from Azusa Light & Water:
http://www.ci.azusa.ca.us/index.aspx?nid=368.
89 DuraTherm -The Spa Depot. (2015). Spa Covers. Retrieved from SpaDepot.com: http://www.spadepot.com/docs/spa-
cover-energy-conservation.pdf.
90 U.S. DOE. (2015, April 27). Insulation. Retrieved from Energy.Gov: http://energy.gov/energysaver/articles/insulation.
71
The foam core is typically made of polystyrene91. Polystyrene is a colorless, transparent
thermoplastic92. There are two types of rigid polystyrene that are used as foam cores for spa
covers: expanded polystyrene (EPS) and extruded polystyrene (XPS). EPS is composed of small
plastic beads that are fused together by heat and pressure leaving open voids between the
beads, whereas XPS begins as a molten material that is extruded into a closed cell matrix (no
spaces between cells). Both have different performance properties due to their manufacturing
process.
XPS is less water absorbent than EPS. The voids in EPS allow for significant water to be
absorbed. When the foam absorbs water, the insulation loses its thermal resistance. Water can
also freeze and thaw compromising the structural integrity of the foam. XPS also has a higher
R-value than EPS when dry or wet. Dry EPS R-value ranges from 3.1 to 4.3 per inch depending
on the density. The R-value varies for EPS because the smaller the voids, the higher the density,
resulting in a slightly higher R-value. The R-value for XPS is a uniform 5 per inch regardless of
density since the cell structure has no voids93. Most spa covers are made of EPS foam as they
are able to provide enough insulation and keep a rigid structure while being resistant to mold,
mildew, or bacteria growth94. They are also lightweight and require only one person to apply or
remove. Thus, there is an opportunity to improve the insulation of the spa cover with highly
efficient polystyrene that already exists in the market.
The R-value of a spa cover can also be increased by enclosing the foam core with a waterproof
barrier, such as vinyl95. Other measures are available to prevent waterlogging and to reduce the
conductive heat flow96. These options are to enclose the foam core within a polyethylene
(common plastic wrap) wrap or a radiant barrier. The plastic wrap prevents water absorption
and exposure to water treatment chemicals. A radiant barrier uses a highly reflective material
that re-emits heat rather than absorbing it (Figure 1997) Examples of the type of enclosures and
combination of barriers are shown in Figure 20.
92 U.S. Department of Energy. (2015, April 27). Insulation Materials. Available at Energy.Gov
http://energy.gov/energysaver/articles/insulation-materials.
93 Owens Corning Foam Insulation, LLC. (2013). Technical Bulletin: For Foam Plastic Insulation, Extrusion Matters
Performance Equals Resisting Water XPS Performs Better Than EPS. Toledo: Owens Corning.
94 The Foam Factory. (2012, January 18). Insulate and Protect Your Hot Tub With a Custom Polystyrene Cover. Retrieved
from The Foam Factory at https://www.thefoamfactory.com/blog/index.php/insulate-and-protect-your-hot-tub-with-a-
custom-polystyrene-cover.
96 Hot Tub Covers Canada.Ca. (2015). R-Values and Insulation. Retrieved from Hot Tub Covers Canda.Ca:
http://www.hottubcoverscanada.ca/our-spa-covers/hottub-cover-r-values.html.
97 U.S. DOE. (2015, April 27). Insulation Materials. Retrieved from Energy.Gov:
http://energy.gov/energysaver/articles/insulation-materials.
72
Figure 19: Radiant Barrier in a Spa Cover
Heat flow being reflected from the radiant barrier.

Figure 20: Types of Spa Cover Enclosures
These spa covers are examples of different foam core enclosure combinations. All use a vinyl wrap, a moisture barrier
(1), and a heavy duty liner (2). From left to right, the first option shows the foam core (A) being enclosed by barriers (1)
and (2); the second encloses the foam core with a reflective barrier (B) and barriers (1) and (2); and the third option
encloses the foam with a another moisture barrier (C) and barriers (1) and (2).
The design and construction of spa covers varies depending on size and shape, but most covers
have a hinge down the middle which allows the cover to fold in half. The hinge is typically not
insulated, is about two inches wide, and runs the entire length of the cover, making it easy to
fold but also allowing for significant heat loss. This type is known as a dual-hinge or double-
hinge. This heat loss can be avoided by using a single-hinge design or an insulated hinge design.
Figure 21 shows a dual-hinge on the left compared to a single-hinge on the right98.
Statewide Utility Code s and Standards Program. Retrieved July 2015.
73
Figure 21: Dual-Hinge and Single-Hinge Spa Covers
A single-hinge avoids heat loss by elminating the gap at the hinge compared to a dual-hinge.
Source: Portable Electric Spas CASE Report 2014
Another design factor limits the seal between the spa cover and the surface of the unit’s
exterior. The majority of spa covers have a vinyl skirt around the perimeter that overlaps the
exterior of the unit to prevent water and heat from escaping, as shown in Figure 2299
Figure 22: Spa Cover Skirt
The addition of a spa cover skirt (provided there is no obstruction from potential
objects such as a mounted safety rail) reduces heat and water loss by covering
the seal between the cover and the surface of the unit.
California Polytechnic State University, San Luis Obispo, Mechanical Engineering. San Luis Obispo: Andrew Ian Hamill.
74
Another source of reducing energy and water consumption is the use of a floating blanket as
shown in Figure 23. The floating blanket reduces moisture and chemical contact with the
underside of the spa cover. It also acts as another barrier to prevent heat loss and
evaporation100.
Figure 23: Spa Floating Blanket
A floating blanket protects and reduces the work

of the spa cover.
Energy Use
The total energy use, according to the Title 20 test method for portable electric spas, is the
total energy consumed during the default operation mode and not limited to water treatment
cycles over a 72-hour period with the spa cover that comes with unit in use101. Andrew Ian
Hamill of California Polytechnic State University, was able to determine which modes and cycles
contribute most to the total standby power from his analysis of 27 different portable electric
spas using the Title 20 test method. The modes, or cycles, were categorized in four groups:
heater cycle, filtration cycle, pulses cycle, and constant filtration cycle.
The heater cycle uses the heater along with the pumps to maintain the water at a set
temperature range. The filtration cycle uses the pumps to draw the water into the filter and
circulate the water to keep the water clean for a set period. The pulses cycle uses the pumps to
circulate the water for a short period. The constant filtration cycle uses the pumps to
continuously circulate water providing filtration and preventing bacterial growth. Hamill’s
results, shown in Table 18, confirm that over half of the energy consumed is due to the heating
100 Lara, D. (2014, April 10). Increasing the Energy Efficiency of Your Hot Tub or Spa. Retrieved from Hot Tub Works:
http://www.hottubworks.com/blog/increasing-the-energy-efficiency-of-your-hot-tub-or-spa/.
101 California Energy Commission, 2015 Appliance Efficiency Regulations. Title 20, Section 1604(g)(2). May 2014.
75
during standby mode. The percent contribution to the standby power using the heater cycle
ranged from 8 to 100 percent of total power. The power demand for the heater cycle ranged
from 706 to 4,331 watts, with a median demand of 3,141 watts for spas with capacities ranging
from 142 to 470 gallons102.
Table 18: Percent Contributions to the Total Standby Power by Cycle Type
Constant
Heater Cycle Filter Cycle Pulses
Filtration
Average Percent
Contribution to 72 24 40 4
Standby Power
The percentages in the table above are not to be summed to equal one hundred percent. Each percentage describes the
overall average percent contribution to each cycle type for the 27 portable electric spas that were tested during standby
mode.
Source: Measurement and Analysis of the Standby Power of Twenty-Seven Portable Electric Spas, Andrew Ian Hamill
It is important to note the volume capacity range of the units tested because there are more
than 130 portable electric spas with a volume size greater than 470 gallons and up to 2,355
gallons that would have a greater power demand during the heating cycle.
76
Chapter 12: Regulatory Approaches
Current Title 20 Standards

In 2004, the Energy Commission adopted standards and testing procedures for portable electric
spas that took effect in 2006103. These standards require that a spa’s standby power must not
exceed a sliding scale of wattage as a function of the spa’s volume [5 x Volume2/3].
Federal Approaches
Currently, there is no federal standard and no ENERGY STAR specification for portable electric
spas.
Other State Approaches

In 2010, Florida adopted the ANSI/APSP/ICC-14 2011 standard for portable electric spa energy
efficiency, which took effect March 15, 2012. This test procedure is based on the test procedure
in the Title 20 Appliance Efficiency Regulations and elaborates more on how testing and
measurements are to be performed104.
Effective January 1, 2012, portable electric spas sold in Arizona cannot exceed a normalized
standby power consumption of the spa’s fill volume raised to the two-thirds power based on
ANSI/APSP/ICC-14 2011105.
Industry Standards
The spa industry, represented by the APSP, has accepted ANSI/APSP/ICC-14 2014 which was
approved by the American National Standard Institute (ANSI) on September 12, 2014, a revision
of ANSI/APSP/ICC-14 2011106. In general, the ANSI/APSP/ICC-14 2014 standard is similar to the
Energy Commission’s Title 20 standard, with a few exceptions: ANSI/APSP/ICC-14 requires a
more stringent standby power limit, requires labels on all spas, applies to exercise spas, and
modifies the test chamber certification testing. The ANSI/APSP/ICC-14 standards represent best
industry practice, but are not mandatory or enforced.
103 California Energy Commission, 2015 Appliance Efficiency Regulations. Title 20. May 2014.
104 APSP. "APSP Standard Becomes Federal Law Through the Virginia Graeme Baker Pool and Spa Safety Act" August 8,
2011. APSP. September 21, 2015. <http://apsp.org/portals/0/PDfs/714.pdf>.
105 Arizona State Legislature. Title 44, Chapter 9, Article 19, 1375.02. Retrieved from
http://www.azleg.gov/FormatDocument.asp?inDoc=/ars/44/01375-02.htm&Title=44&DocType=ARS.
106 APSP, American National Standards Institute. (2014). American National Standard for Portable Electric Spa Energy
Efficiency. Alexandria: APSP.
77
The CASE Report
In July 2013, the IOUs and the Natural Resources Defense Council submitted a CASE report to
the Energy Commission in response to the Commission’s invitation to submit proposals107. In
May 2014, they submitted a revised proposal for portable electric spa standards108. The
proposal recommends adopting the ANSI/APSP/ICC-14 2014 standard, with the exception of
regulating exercise spas. More specifically, they recommend adopting the test procedures, test
room requirements, and a lower standby power limit [3.75 x Volume2/3 + 40 watts] stated in the
ANSI/APSP/ICC-14 2014 standard. In addition, the CASE report recommends adding
requirements for original equipment and third-party spa covers, and requiring labels on spa
units which will inform consumers of the tested standby power consumption, maximum
allowable standby power consumption, and the spa cover make and model used during testing
to achieve the displayed standby performance.
The CASE team estimates that implementing the recommended proposal would result in a
reduction of about 6 GWh the first year the standards are in effect and a savings of about 64
GWh after full-stock turnover in 10 years.
107 CASE Report, Pools & Spas (July 29, 2013). Retrieved from:
108 CASE Report, Portable Electric Spas. (May 15, 2014). Retrieved from:
http://www.energy.ca.gov/appliances/2013rulemaking/documents/comments/12-AAER-
2G_Portable_Electric_Spa_Labeling/12-AAER-2G_Portable_Electric_Spas_Final_CASE_Report_2014-05-15_TN-73027.pdf.
78
Chapter 13: Alternative Considerations
Staff analyzed the proposal in the CASE report to determine whether it meets the legislative
criteria for the Energy Commission’s prescription of appliance efficiency standards. Staff also
reviewed and analyzed state standards for three scenarios (1) maintaining current Title 20
standards, (2) incorporating the CASE report’s proposal, and (3) modifying the scenario
proposed by the CASE team.
Alternative 1: Maintaining Current Title 20

Staff visited residential spa show rooms at the California State Fair in 2013 and witnessed spas
that were offered for sale carrying labels that described the products as “efficient” without any
explanation of why or how they were rated. This type of labeling leaves consumers without any
means to make an educated purchase related to the efficiency of the unit.
As mentioned earlier, dealers are not required to purchase original equipment covers to provide
to consumers. Instead, they can purchase third-party spa covers and offer them to consumers
as a lower cost option and for a profitable margin. Therefore, if a cover does not have the
ability to prevent heat loss due to evaporation as it should, spa performance integrity (as tested
and certified) may be compromised. This could undermine the effectiveness of the current
portable electric spa standard.
Because of these reasons, staff believes the Title 20 standards must be updated.
Alternative 2: Incorporate CASE Team Proposal

The CASE Team proposal would establish a more efficient energy consumption standard for
portable electric spas (not including exercise spas), adding requirements for specific effective
spa covers, adding a labeling requirement to provide consumers with tools for informative
purchases, and updating testing procedures. Specifically, the proposal recommends:
 Establishing more efficient spas by lowering standby power consumption limit. The
current standard of [5xV2/3] should be changed to [(3.75xV2/3) + 40], consistent with the
most recent version of ANSI/APSP/ICC-14 2014. The new proposed standard allows
reduction of heat losses from the spa surface area while supporting the minimum
baseline energy consumption needed to operate other equipment, such as the pump and
controller.
 Incorporating ANSI/APSP/ICC-14 2014 as the new test method and labeling template for
compliance verification.
 Adding a clarifying requirement that would require new spas to be sold with a cover.
 Reporting and listing approved spa covers used during certification testing.
79
This proposal presents a significant opportunity for energy savings that are both cost-effective
and technically feasible. A potential drawback to this alternative is the prohibition of selling spa
covers with new insulation technology, third-party spa covers that are not indicated as
approved by the manufacturer, or spa covers that are not listed with spa units in the Appliance
Efficiency Database. If a customer could purchase only the test cover or manufacturer-approved
third party cover shown in the Appliance Efficiency Database, there could be an increase in the
incremental cost in addition to meeting the more stringent standby consumption standard and
label requirement. Customers who would rather purchase a better-insulating cover would not
have that option until after purchasing the standard cover.
Alternative 3: Updated Standby Standards with Spa Cover

Reporting and Labeling
Staff evaluated the CASE team’s proposal and analyzed the data of certified portable electric
spas and exercise spas in the Appliance Efficiency Database to see if the proposed standby
energy consumption standard could be extended to all portable electric spa types as 70 percent
of the certified exercise spas sold in California would meet the new standard. Alternative 3
includes recommendations similar to the CASE Team’s proposal.
 The current standard of [5xV2/3] should be changed to [(3.75xV2/3) + 40] for all types of
portable electric spas.
 Incorporate ANSI/APSP/ICC-14 2014 as the new test method as well as the labeling
template included within the new test method for compliance verification.
 The label template shall display the manufacturer and model number of the test spa
cover used during certification testing on the spa unit label.
 The model number of the same test cover used during testing shall be reported during
the data submission process which would remain in conjunction with the current Title
20 test method requiring that each spa unit shall be tested with the spa cover that
comes with the unit.
This alternative achieves a similar amount of energy savings to the CASE report while
addressing the limitations posed by the spa cover. Alternative 3 would allow consumers to
purchase a spa cover of their choice. Prior to purchase, the consumer would be informed of
what cover should be bought with the unit to achieve the standby performance that was labeled
and reported for certification and sale in California.
80
Chapter 14: Staff Proposed Standards for
Portable Electric Spas and Exercise Spas
Energy Commission staff has analyzed the cost-effectiveness and technical feasibility of the
standards proposed in the CASE report, and based on this information along with further
analysis, staff proposes a similar standard with some modifications for labeling and testing spa
covers. The proposed standard is for all portable electric spas, including exercise spas,
manufactured on or after January 1, 2018, or one year from the adoption date, whichever is
later.
Based on independent analysis of the best available data, including that from the CASE report,
staff concluded that the proposed regulations are both cost-effective and technically feasible.
Staff assumptions and calculation methods are provided in Appendix B.
Scope
Staff recommends updating the portable electric spa definition to clarify that all types of
portable electric spas are included, including exercise/swim/combination spas and inflatable
spas.
Test Procedure
All portable electric spas shall be tested in accordance with ANSI/APSP/ICC-14 2014, with the
exception of the swim spa standby consumption limit in Section 6.3 of the test procedure. A
uniform standby consumption limit will be applied to all portable electric spa types.
The proposal to use the test procedure ANSI/APSP/ICC-14 2014 is based on a collaborative
effort dating back to 2005. This effort included the APSP, leading portable spa manufacturers,
and the Energy Commission, Davis Energy Group, and the IOUs. The test procedures in this
standard are based on that effort and the test method for portable spas described in Section
1604 of Title 20, California Code of Regulations, as amended December 3, 2008. To further
support the claims in this standard, the portable spa manufacturers, working through APSP,
conducted research and testing of the energy efficiency of portable spas. The standard was
109
prepared in accordance with ANSI .
109 APSP, American National Standards Institute. American National Standard for Portable Electric Spa Energy
Efficiency. Alexandria: APSP, 2014.
81
Standby Power Consumption
All portable electric spas shall not exceed the normalized standby power consumption of
[(3.75xV2/3) + 40].
Changing the standby power limit from [5xV2/3] to [(3.75xV2/3) + 40] will save a size-weighted
average of 8 percent of energy consumption according to the CASE Team. The CASE Team
selected this standard level after working with spa manufacturers and the APSP-14 Committee.
As a result of their conversations with various spa manufacturers, the CASE Team, along with
Energy Commission staff, believes this proposed standard “addresses industry’s concerns of
smaller spas being disproportionally impacted by a potential updated standard, while
110
significantly tightening the standard on larger spas .”
Labeling Requirements
The label shall meet the design and specification listed in Section 7 of the ANSI/APSP/ICC-14
2014 with wording modifications (refer to Chapter 18). The spa shall be marked by the
manufacturer where readily visible on the shell or front skirt panel during the point of sale. The
marking shall be on a removable adhesive backed label and shall only be removed by the
111
consumer .
Staff proposes using a categorical or continuous label for portable electric spas. A categorical
label uses a ranking system that allows consumers to tell how energy efficient a model is by
using multiple classes that progress from least efficient to most efficient or most energy
consuming to least energy consuming. A continuous label uses a bar graph or line scale which
allows consumers to see where the unit fits into the full range of similar models. The CASE
team collaborated with APSP-14 committee and designed a spa energy label shown in Figures
24 and 25 below112. For more details on the information present on the label, refer to
Appendix B.
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, Pacific Gas &
Electric Company. California Statewide Utility Codes and Standards Program. Retrieved July 2015.
111 APSP, American National Standards Institute. (2014). American National Standard for Portable Electric Spa Energy
Efficiency. Alexandria: APSP.
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, Pacific Gas &
Electric Company. California Statewide Utility Codes and Standards Program. Retrieved July 2015.
82
Figure 24: Label Design
Source: ANSI/APSP-2014
Codes:
a. Spa manufacturer
b. Spa model
c. Spa volume
d. Standby power
e. Standby power chart arrow location and standby power value
f. Maximum standby power allowed
g. Total annual power consumption in standby mode
h. Annual standby energy cost
i. Specified cover manufacturer
j. Specified cover model
83
Figure 25: Label Specifications
Source: ANSI/APSP-2014
Figure 25 shows the design specifications for the label format.
 Label shall be printed on a removable adhesive-backed white polymer label or the

equivalent.
 Text color shall be black. Leaf color: equivalent to Pantone 363 green (also permitted to
be black) Water color: equivalent to Pantone 7691 blue (also permitted to be black.)
 Label codes:
a. Label shall be printed on a white label with black text

b. Minimum label width: 5 inches
c. Minimum label height: 6.25 inches
d. Leaf color: equivalent to Pantone 363 green (also permitted to be black)
84
e. Water color: equivalent to Pantone 7691 blue (also permitted to be black)
f. Font: Helvetica Neue Black. Character height shall not be less than 15 pt type
g. Font: Helvetica Neue Black. Character height shall not be less than 24 pt type
h. Font: Arial Bold. Character height shall not be less than 9.5 pt type
i. Font: Arial Bold. Character height shall not be less than 16 pt type
j. Font: Arial Bold. Character height shall not be less than 12 pt type
k. Font: Arial. Character height shall not be less than 8 pt type, and may be
horizontally scaled to no less than 85 percent
l. Font: Arial Bold. Character height shall not be less than 8 point type, and may be
horizontally scaled to no less than 85 percent
m. The standby power chart arrow shall be scaled at the appropriate location between
the minimum and maximum power range using the standby power value for the spa
which is being installed.
Spa Cover Labeling and Reporting Requirements

Staff will require that the same model number of the test cover displayed on the label be
reported during the data reporting and certification process for the Appliance Efficiency
Database.
With the current Title 20 test method, portable electric spas are tested with the “standard cover
that comes with the unit.” Spa covers are typically sold with the purchase of a new spa. The
cover that is sold with the unit is sometimes a cover made by a third party and not the
standard cover used during testing as a way to cut costs for dealers and/or sellers. Also, many
people base their purchasing choice on the lowest retail price which can have a negative effect
on energy consumption and operating costs113. If a lower quality, less energy-efficient spa cover
is purchased by the consumer or sold by a dealer with a spa certified with a higher performance
cover, its certified energy consumption can be compromised114. Thus, labeling the unit with the
cover that the spa manufacturer provides or specifies during testing will educate consumers
and lead to more energy efficient purchasing decisions115.
Statewide Utility Code s and Standards Program. Retrieved July 2015.
115 Ibid.
85
Chapter 15: Savings and Cost Analysis
The proposed updated standards for portable electric spas would significantly reduce
energy consumption, and are both cost-effective and technically feasible. Table 22
summarizes the potential energy savings of the proposed standards. Energy savings are
further separated into first-year savings and stock savings for portable spas and exercise
spas. First-year savings means the annual energy reduction associated with annual sales,
one year after the standards take effect. Annual stock turnover savings means the annual
energy reduction achieved after all existing stock in use complies with the proposed
standards. Staff’s calculations and assumptions used to estimate the first‐year savings and
the stock change savings are provided in Appendix B.
Incremental Costs
The CASE team reported no incremental cost increase in implementing the proposed
standard. However, the label could lead to improved spa covers or more efficient spa covers
to go with a manufacturer’s unit. Thus, staff believes there would be incremental costs
when improving the spa cover and from implementing the standby energy consumption
requirement. When the current standby power limit standard was being proposed in 2004,
various sources estimated incremental costs for portable electric spas, shown in Table 19.
Staff believes that over time these costs have decreased significantly. Staff will use the most
recent estimated incremental costs of $100 by Nadel, deLaski, Eldridge, & Kleisch in 2006.
86
Table 19: Estimated Incremental Costs for Current Standard
Source Incremental Cost
Pope, Rainer, Fernstrom, & Eilert, $750

2002
Davis Energy Group, Energy Solutions, Measure Incremental

2004 Cost
Improved Cover $100
Improved Spa Insulation $200
Improved Motor Configurations $300

and Efficiency
Improved Controls $50
Total $650
Douglas Mahone & Heschong Mahone $300

Group Inc., 2005
Nadel, deLaski, Eldridge, & Kleisch, $100

2006
The CASE report states the cost of labeling portable electric spas with a removable sticker
type label is estimated to be minimal. Using the sources and assumption in the CASE report
for determining labeling costs, staff has estimated the per label cost to be $0.38 per
label116. Details of this estimation are shown in Table 20.
116 Ibid.
87
Table 20: Label Costs for Portable Electric Spas
One Time Set-Up Costs Units
Engineer/Designer Time 40 Hours
Engineer/Designer Hourly Wage $ 44.36 Dollars/Hour
Set-Up Cost to each Manufacturer $ 1,774 Dollars
Number of Spa Manufacturers 43 Manufacturers
Total Set-Up Cost Statewide $ 76,299 Dollars
Material Cost Units
Printing Costs 0.22 Dollars/Label
Portable Electric
2017 Stock* 596,776 Spa Units
Total Printing Costs to Label Stock $ 131,291 Dollars
Labor Costs to Apply Label Units
Time to adhere each Label 8 Seconds
Total time to adhere Labels to Entire Stock 1,326 Hours
Packaging and Filling Machine Operators Hourly Wage $ 13.44 Dollars/Hour
Total Labor Costs $ 17,824 Dollars
Total Units
Total Cost to Label Stock $ 225,414 Dollars
Label Cost per Unit $ 0.38 Dollars/Label
Source: Staff calculation using information from Portable Electric Spas CASE Report 2014
*Stock is based on the year 2017 when the assumption for the effective was July 1, 2017.
Lifecycle costs and benefits of the proposed standard for portable electric spas and
exercises spas are shown in Table 21. Lifecycle costs are based off the estimated
incremental costs for improving the unit and labeling costs. The lifecycle benefit represents
the savings the consumer should receive over the life of the appliance. Lifecycle benefits are
based off of comparing the weighted-average standby power consumption under the
current standard with respect to the proposed standard.
Table 21: Weighted Unit Energy Savings and Lifecycle Benefits

Design Electricity Lifecycle Lifecycle Lifecycle
Life Savings Costs Benefit Benefit/Cost
(years) (kWh/year) ($/unit) ($/unit) Ratio
Portable Electric Spas 10 317 $ 100.38 $ 512 5
Exercise Spas 10 1,451 $ 100.38 $ 2,349 23
Source: Staff calculations, see Appendix B
In conclusion, the proposed standard is cost‐effective as the compliant product has a high
benefit-to-cost ratio.
88
Standby Power Efficiency Savings
As summarized in Table 22, if all portable electric spas complied with the proposed
standards (annual stock turnover savings), California would save 61 GWh of energy per
year. Using a residential rate of $0.16 per kWh of electricity, it is estimated that
implementation of the proposed standards for portable electric spas would achieve roughly
$10 million a year in reduced utility costs after full implementation. In more detail, exercise
spas contribute 8 GWh of energy savings per year and $1 million per year in reduced utility
costs after full implementation. Due to lack of market inventory and operational data for
exercise spas, these estimates could be underrepresenting the actual energy savings.
Table 22: Standby Power Standard Statewide Annual Stock Savings

First‐Year Savings Complete Turnover Savings
Energy Savings Energy Savings
Consumption ($ million) Consumption ($ million)
(GWh/yr) (GWh/yr)
Portable Electric 4.22 0.68 53 9
Spas (Zones 1‐3)
Exercise Spas 0.62 0.10 8 1
(Zones 4‐8)
Total 4.84 0.78 61 10
Source: Staff calculation, see Appendix B
Spa Cover Savings

Savings from using a spa cover versus not using a spa cover are presented separately since
the performance standard relies on a spa cover to meet the performance standard. Staff
calculated evaporation rates using industry standard methods. Table 23 presents the
evaporation rate, energy lost, and energy cost for a typical five-person spa left uncovered
year round.
Table 23: Energy Cost for Uncovered Spa

Design Unit
Evaporation Energy Energy Life of
Water Wasted Estimated Savings
Rate, wp Consumption Costs Spa Cover Spa Cover with Spa
(gallons/year) (years)
(gallons/hr) (kWh/year) ($) Price ($) Cover
($/yr)
1 21,688 8,760 $3,511 $500 5 $3,411
Source: Staff calculations, see Appendix B
89
Spa Labeling Savings
The MAEDBS shows that units with the same volume capacity have very different standby
energy consumption values. The range can go up to 150 watts for units with the same
volume capacity117. This wide range of standby power consumption is impacted by factors
such as the spa cover, construction materials, and design of the unit. Consumers may be
unaware that a wide range exists and must rely on the information given by the seller and
manufacturer. Thus, consumers can benefit from having a label affixed to the unit to inform
them of the energy consumption and energy savings. Labeling programs such as ENERGY
STAR and “EnergyGuide” have proven to be successful at providing consumers with energy
saving information which can lead to purchasing decisions that increase energy efficiency.
In addition to a spa model number being listed in the Appliance Efficiency Database, a label
will inform the consumers that the unit meets California’s appliance efficiency standards
and is certified to be sold in California118.
Labeling portable electric spa units will lead to energy savings by educating consumers and
as a result choosing a more efficient unit. However, determining how many consumers will
choose a more efficient unit, how much more efficient a unit they choose, and how the label
impacts that decision is somewhat more of an art than a science. An estimated 5 percent of
the total energy consumption is said to be the potential savings119. This estimate is based
on half of the 10 percent improvement in sales-weighted average efficiency for refrigerators
using the categorical European Union (EU) Label scheme120. Table 24 presents the savings
when applying the potential 5 percent savings by affixing a label to portable electric
spas121.
117 California Energy Commission. (2015). Modernized Appliance Efficiency Database System. Retrieved from
Appliance Search: http://maedbs/Pages/ApplianceSearch.aspx.
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, PG&E.
California Statewide Utility Code s and Standards Program. Retrieved July 2015.
119 Ibid.
120 Bertoldi, Paolo. Energy Efficient Equipment within SAVE: Activities, strategies, success and barriers. Brussels:
European Commission, 2000.
121 “European Union Efforts to Promote More Efficient Use of Electricity: the PACE Programme." 1996 Summer
Study on Energy Efficiency in Buildings. Washington, D.C.: American Council for an Energy-Efficient Economy,
1996.
90
Table 24: Statewide Annual Stock Savings Adjusting for Label Impact
First-Year Savings Complete Turnover Savings
Energy
Energy Consumption
Savings Savings
Consumption
(Million$) (Million $)
(GWh/yr)
(GWh/yr)
Portable Electric 5.7 0.9 69.6 11.2
Spas
Exercise Spas 0.8 0.1 10.4 1.8
Total 6.5 1.0 80 13
Source: Staff calculation, see Appendix B
91
Chapter 16: Technical Feasibility of
Proposed Standards for Portable Electric
Spas
As of July 2015, the Energy Commission database lists over 1,100 portable electric spas,
over 70 percent of which would meet the proposed standards. Table 25 shows a breakdown
of the compliance rate for the portable electric spas in the MAEDBS. The quantity and
variety of compliant spas available for sale are an indication that compliant products are
technically feasible and readily available in California.
As Figure 26 demonstrates, a significant number of existing spas would meet the proposed
standard, demonstrating that it is technically feasible.
Figure 26: Portable Electric Spas in the MAEDBS
This graph displays all of the portable electric spas that are certified using the current Title 20 standard and
whether they meet the proposed standard.
Source: MAEDBS, California Energy Commission
92
Table 25 details the compliance rate illustrated in Figure 27. The CASE report stated 29
percent of the portable electric spas in the MAEDBS would not meet the proposed standard
limit, which is similar to the results in Table 25.
Table 25: Compliance Rate of Portable Electric Spas

Zones Compliant (%) Non-Compliant (%)
Portable Spas 1AB to 3 72.2 27.8
Exercise Spas 4 to 8 69.7 30.3
All Certified
1AB to 8 72.1 27.9
Units
Compliance rate of the proposed standard for certified portable electric spas.
The energy consumption of portable electric spas can be optimized by employing better
insulation, better-designed covers, and the use of a more efficient pump for circulation and
filtration.
Insulation
Most manufacturers already insulate the shell and base of spas using high R-value
insulation materials. According to the Energy Commission database, over 99 percent of spas
listed are fully insulated.
Staff found that units with the same volume capacity have very different standby energy
consumption values, up to 150 watts. Staff believes the cause of this difference is in the
method and materials of insulation. For example, hit and miss spots at the shell and base of
spas can largely reduce the effectiveness of insulation. Therefore, improvements on the
method of applying uniform insulation would improve the efficiency of the unit.
Implementing this improvement would decrease energy use by up to 30 percent for a spa of
average-to-low efficiency. This is also the easiest method to implement since it requires
little additional engineering and design work122.
The CASE report also identified that manufacturers use a combination of closed cell foam
and radiant barriers, instead of fiberglass, which can help reduce the heat loss123.
Spa Covers
Improvements to spa covers, such as using high R-value and less water absorbent
insulation, adding radiant barriers, and better sealed covers, can reduce heat and water loss
122 Davis Energy Group, Energy Solutions. (2004). Analysis of Standards Options for Portable Electric Spas.
California: PG&E.
Standards Development- Analysis of Standards Proposal for Portable Electric Spas. Energy Solutions, PG&E.
California Statewide Utility Codes and Standards Program. Retrieved July 2015
93
from the spa, and already exist in the industry. In addition, improving the construction and
design work of the spa cover such as using single-hinged or insulated hinge covers instead
of double-hinged, can yield additional efficiency savings124.
Pump and Motor

Manufacturers have used waste heat from circulation pumps to replace separate heating or
to supplement heating of water, which can greatly improve the efficiency of spas125. Also,
most spa manufacturers of large portable electric spas add a separate low-wattage
circulation pump to run specific cycles. This addition can save approximately 15 percent of
the energy consumption and up to half of the pumping energy used for circulation and
filtering. Other options include improved pump efficiency with advanced multi-speed motor
designs, and using variable-speed motors and controls. Options like these would require
manufacturers to invest in product development and design work, which would most likely
begin after insulation improvement126.
124 Ibid.
125 Ibid.
126 Davis Energy Group, Energy Solutions. (2004). Analysis of Standards Options for Portable Electric Spas.
California: PG&E.
94
Chapter 17: Environmental Impacts
Environmental Impacts
Spas are replaced when they are at the end of their useful lives; replacement of these
appliances would present no additional impact to the environment beyond their natural
cycles.
Benefits
Staff estimates that the proposed standards will result in reductions of almost 15 tons of
criteria air pollutants and 49,000 tons of GHG emissions due to the avoided energy used.
Staff tabulated the criteria for air pollutant and GHG emissions reductions in Table 26
using the annual statewide stock savings energy consumption after complete turnover
values listed in Table 22 and 24.
Table 26: Greenhouse Gas Emissions Reductions

Annual Avoided Emissions (tons)
Oxides of Sulfur Carbon Particulate Total Air
Greenhouse
nitrogen dioxide monoxide matter Pollutants
Gas (eCO2)
(NOx) (SOx) (CO) (PM2.5)
Portable
4.3 0.6 6.2 1.8 12.9 42419
Electric Spas
Exercise Spas 0.6 0.09 0.9 0.3 1.9 6210
Total 4.9 0.69 7.1 2.1 14.8 48629
Source: Emission factors from the ARB
95
Chapter 18: Regulatory Language
The following shows staff’s proposed changes to the portable electric spa standard.
Underlines mean new added text and strike outs mean deleted text.
Section 1602(g) Definitions
“Portable electric spa” means a factory-built and free-standing electric spa or hot tub,
supplied with equipment capable of for heating and circulating the water inside a rigid,
flexible, or inflatable shell.
“Combination spa” means a portable electric spa with separate bodies of water capable of
heating each body of water at different temperatures.
“Exercise spa” (also known as an “endless pool” or “swim spa”) means a portable electric
spa designed to produce a water flow intended for water therapy or fitness training,
including swimming in place.
“Spa volume” means the actual fill volume of the spa, under normal use, in gallons, as
defined in the test method in Section 1604(g)(2)(B).
Section 1604(g)(2) Test Method for Portable Electric Spas.
(A) The test method for portable electric spas manufactured on or after January 1, 2006,
and before January 1, 2018, is as follows:
(i) (A) Minimum continuous testing time shall be 72 hours.
(ii) (B) The spa shall be filled with water to the halfway point between the bottom of the
skimmer basket opening and the top of the spa. If there is no skimmer basket, the
spa shall be filled with water to six inches below the top of the spa.
(iii) (C) The water temperature shall be 102°F, ± 2°F for the duration of the test.
(iv) (D) The ambient air temperature shall be 60°F, ± 3°F for the duration of the test.
(v) (E) The standard cover that comes with the unit shall be used during the test.
(vi) (F) The test shall start when the water temperature has been at 102°F, ± 2°F for at
least four hours.
(vii) (G) Record the total energy use for the period of test, starting at the end of the first
heating cycle after the stabilization period specified in Section 1604(g)(2)(AF)(vi), and
finishing at the end of the first heating cycle after 72 hours has elapsed.
96
(viii) (H) The unit shall remain covered and in the default operation mode during the
test. Energy‐conserving circulation functions, if present, must not be enabled if not
appropriate for continuous, long‐term use. Ancillary equipment including, but not
limited to lights, audio systems, and water treatment devices, shall remain
connected to the mains but may be turned off during the test if their controls are
user accessible.
(ix) (I) The measured standby power shall be normalized to a temperature difference of
37°F using the equation,
Δ
Pnorm = Pmeas
Δ
Where:
Pmeas = measured standby power during test (E/t)
ΔTideal = 37°F
ΔTmeas = Twater avg – Tair avg
Twater avg = Average water temperature during test
Tair avg = Average air temperature during test
(x) (J) Data reported shall include: spa identification (make, model, S/N, specifications);
volume of the unit in gallons; supply voltage; minimum, maximum, and average
water temperatures during test; minimum, maximum, and average ambient air
temperatures during test; date of test; length of test (t, in hours); total energy use
during the test (E, in Wh); and normalized standby power (Pnorm, in watts).
(B) All portable electric spas manufactured on or after January 1, 2018, shall be tested in
accordance with ANSI/APSP/ICC-14 2014, with the exception of Section 6.3.
Section 1605.3 (g)
(6) Portable Electric Spas
(A) The normalized standby power, as defined in Section 1604(g)(2)(AI)(ix), of portable

electric spas manufactured on or after January 1, 2006, and before January 1, 2018, shall be
not greater than 5(V2/3) watts where V = the fill volume, in gallons.
(B) The normalized standby power, as defined in ANSI/APSP/ICC-14 2014, of portable

electric spas manufactured on or after January 1, 2018, shall not be greater than [3.75(V2/3) +
40] watts where V = the fill volume, in gallons.
97
Section 1606(a)(3)(c)
Table X – Data Submittal Requirements

G Appliance Required Information Permissible Answers
Portable Electric Spas *Voltage
Volume (gallons)
Rated Capacity (number of people)
Normalized Standby Power (watts)
Spa Enclosure is Fully Insulated Yes, No
Tested Spa Cover Model

*”Identifer” information as described in Section 1602(a).
Section 1607(d) Energy Performance Information.
(12) Portable Electric Spas
The spa shall be marked by the manufacturer where readily visible on the shell or front
skirt panel. The marking shall be on a removable adhesive backed label and shall only be
removed by the consumer. The label shall meet the design and specification listed in Section
7 of the ANSI/APSP/ICC-14 2014 with the exception of the wording in Section 7.2.1 Part I.
The label language for Section 7.2.1. Part I shall be:
This spa was tested with the spa manufacturer’s specified cover:
Tested Cover Manufacturer: xxx
Tested Cover Model: xxx
The following documents are incorporated by reference in Section 1607.
Number Title
THE ASSOCIATION OF POOL AND SPA PROFESSIONALS (APSP)
ANSI/APSP/ICC-14 2014 American National Standard for Portable Electric Spa

Energy Efficiency
Copies available from: The Association of Pool and Spa Professionals

2111 Eisenhower Avenue
Alexandria, VA 22314-4695
www.apsp.org
Phone: (703) 838-0083
98
Appendix B: Staff Assumptions and
Calculation Methods
Appendix B discusses the information and calculations used to characterize portable

electric spas in California, the current energy use, and potential savings. The source of
much of this information is the CASE report submitted to the Energy Commission. All
calculations were based on the assumption of an effective date of January 1, 2017, although
the effective date is January 1, 2018. The difference in effective dates does not significantly
alter the calculations. After careful review, staff has altered some of the figures from the
CASE report as appropriate to fit staff’s approach to energy consumption and savings.
99
Table B-1: Summary of Values and Assumptions
Value Description Source
5.0 % Average Percent of New Units in California APSP, 2012‐2013 (see Table B‐2)
Average percentage of California Spa
44.0% Owners that own an outdoor, above‐ground KEMA, 2010 (see Table B‐3)
spa
8,760 hrs/year Standby mode operating hours Worth & Fernstrom, 2014
Surface water temperature required for Title
102°F ± 2°F Title 20, Section 1604 (g)(2)
20 test method
Air temperature required for Title 20 test
60°F ± 3°F Title 20, Section 1604 (g)(2)
method
Pw, saturation vapor pressure taken at a
6.95 kPa surface water temperature of 38.89°C or Brice & Hall, 2014
102°F
Pa, saturation vapor pressure at room
1.768 kPa Brice & Hall, 2014
temperature of 15.56°C or 60°F
Recommended air velocity over water
0.10 m/s Lund, 2000
surface
1.0 Activity factor for whirlpools and spas Lund, 2000
Number of Manufacturers who have
43 certified portable electric spas in the MAEDBS July 2015
MAEDBS
Average Residential Retail Price in California U.S. Energy Information
0.1619 $/kWh
for Electricity Administration, 2013
Assumption made by CASE Team,
5.0% Label Impact Rate Savings Portable Electric Spas CASE Report
2014
0.07 lb/MW Oxides of nitrogen emission factor California Air Resources Board, 2010
0.01 lb/MW Sulfur Dioxide emission factor California Air Resources Board, 2010
0.10 lb/MW Carbon Monoxide emission factor California Air Resources Board, 2010
0.03 lb/MW Particulate matters emission factor California Air Resources Board, 2010
Energy Aware Planning Guide as
cited in Staff Analysis of Water
690.00 lb/MW Carbon Dioxide emission factor
Efficiency Standards for
Showerheads 2015 Report
Stock and Sales

Table B-2 lists annual stock and annual sales for portable electric spas in California during
2011 and 2012.
100
Table B-2: Number of Portable Electric Spa Units in California
New Units Percent of
Stock in
Year Sold/Installed New Units in
California
in California California
2011 1,488,016 71,525 4.8%
2012 1,142,352 58,922 5.2%
Average 5.0%
Units include commercial, in-ground, and above-ground.

Source: APSP - U.S. Swimming Pool and Hot Tub 2012 and 2013 Market Reports
Table B-3 lists the number of outdoor, above-ground spas in California from the 2003 and
2009 Residential Appliance Saturation Study (RASS).
Table B-3: Outdoor and Above-ground Spas in California

Building Type 2003 2009
Single Family 356,265 443,731
Townhouse, Duplex, Row House 8,368 5,725
Apt Condo 2-4 Units 2,002 5,498
Apt Condo 5+ Units 531 3,877
Mobile Home 6,181 8,162
Other 1,366 227
Total Outdoor and Above-ground spas 374,713 467,220
Total of California Residents that own a spa 804,660 1,102,560
Percent of California Spa Owners that own 47% 42%

an outdoor, above-ground spas
Average 44%
Source: California Statewide Residential Appliance Saturation Study
Using information from the Residential Energy Consumption Survey (RECS) database by U.S.
Energy Information Administration from 1993 to 2009, APSP U.S. Swimming Pool and Hot
Tub Market Reports, and the 2009 Residential Appliance Saturation Study, staff estimated
the annual stock and sales in California, shown in Table B-4.
101
Table B-4: Estimated Annual Stock and Sales
Year Stock of Spas Stock of Sales

in California1 Portable Electric
Spas in
California
2012 1,142,352 508,026 25,312

2013 1,182,265 525,776 26,196
2014 1,222,178 543,526 27,080
2015 1,262,091 561,276 27,965
2016 1,302,004 579,026 28,849
2017 1,341,917 596,776 29,733
2018 1,381,830 614,526 30,618
2019 1,421,743 632,276 31,502
2020 1,461,656 650,026 32,387
2021 1,501,569 667,776 33,271
2022 1,541,482 685,526 34,155
2023 1,581,395 703,276 35,040
2024 1,621,308 721,026 35,924
2025 1,661,221 738,776 36,808
2026 1,701,134 756,527 37,693
2027 1,741,047 774,277 38,577
2028 1,780,960 792,027 39,462
2029 1,820,873 809,777 40,346
2030 1,860,786 827,527 41,230
1
Stock includes commercial, in-ground, and above-ground units
2
Stock of units outdoor and above-ground using RASS reports esimates.
3
Using APSP report estimates.
Source: See Table B-2 and Table B-3, RECS database
Design Life
The design life is an estimate of the length of a product’s typical operation usefulness. The
design life figures were taken from the CASE report and are shown in Table B-5.
Table B-5: Estimated Design Life of Non-Inflatable, Portable Electric Spas

Component Design Life (years)
Spa Cover 5
Portable Electric Spa 10
Source: Portable Electric Spa CASE Report 2014
102
Compliance Rates
Compliance rate is the percentage of compliant units over the total stock units. Table B-6
lists the estimated or reported compliance rates. A compliance rate is percentage indicates
the ratio of compliant appliances to the total market or stock. Thus, a compliance rate of 40
percent means that 40 percent of that particular appliance already meets the proposed
standard.
Table B-6: Compliance Rate for Portable Electric Spas

Zones Compliant (%) Non-Compliant (%)
Portable Spas 1AB to 3 72.2 27.8
Exercise Spas 4 to 8 69.7 30.3
All Certified
1AB to 8 72.1 27.9
Units
Compliance rate of the proposed standard for certified portable electric spas.
Table B-7 lists the estimated compliances rates for each zone.
Table B-7: Unit Population and Compliance Rate for each Zone
Total Units
Non- Non-
Compliant Units per Compliant
Zones Compliant Compliant
Units Zone (%)
Units (%)
(%)
1A* 59 0 59 5 95 5
1B 281 54 335 28.4 83.9 16.1
2 479 257 736 62.37 65.1 34.9
3 9 8 17 1.44 52.9 47.1
4* 0 1 1 0.08 5 95
5 6 2 8 0.68 75 25
6 12 2 14 1.19 85.7 14.3
7 2 3 5 0.42 40 60
8 3 2 5 0.42 60 40
Total 1,180 100

*Conservative compliance rate
103
Duty Cycle
The duty cycle of an appliance is an estimate of consumer behavior for that particular
appliance. It is directly tied to how often the appliance is used and for how long. In the
context of this report, the duty cycle is the usage of the regulated standby mode or cycle of
the unit. The duty cycle used in this report are taken directly from the CASE report and
applied to both portable electric spas and exercise spas.
Table B-8: Duty Cycle

Unit Operating Hours
Portable Electric Spas 8,760 hrs/yr
Exercise Spas 8,760 hrs/yr
Source: Portable Electric Spas CASE Report 2014
Baseline Energy Use

After applying the proposed standby power limit to the certified units in the MAEDBS
displayed in Figure 27, the graph shows a high saturation of data on the lower left which
could cause some discrepancies in calculating energy consumption. Also, the CASE report
does not include portable electric spas with a volume of more than 800 gallons, which is
taken into account. The units currently in the MAEDBS are certified under the current Title
20 standard and will fall below the current standard curve. There are cases where units do
not pass the current standard and are not represented in the graph. There could also be
instances in the future where current units will be upgraded or discontinued, therefore
being removed from the MAEBDS. These cases will modify the data, thus using an average
of the standby power consumption of the units in the database as the base for our
calculations would be an inaccurate representation of the energy consumption. Instead of
using a weighted-average of the standby power consumption, we will use a weighted-
average of the maximum allowable standby power from the current and proposed standard
equations.
The current standby power limit equation is as follows:

/
5
where
P = maximum allowable standby power (watts)
V = volume (gallons).
The proposed standby power limit equation is as follows:

/
3.75 40
where
P = maximum allowable standby power (watts)
V = volume (gallons).
104
Table B-9 lists the volume used in the equations above and is the average volume of the
volume range in each zone.
Table B-9: Average Volume used for Calculations

Volume Range Average Volume
Zone
(gallons) (gallons)
1A 100-180 140
1B 181-300 240
2 301-600 450
3 601-900 750
4 901-1,200 1,050
5 1,201-1,500 1,350
6 1,501-1,800 1,650
7 1,801-2,100 1,950
8 2,101-2,400 2,250
Source: Staff calculation
Figure B-1displays the results of inputting the average volume of each zone into the
standby power limit equation for the current and proposed standard. The graph also
displays the standby power limit for the proposed standard when applying the 5 percent
potential savings as a result of adding a label to portable electric spas.
Sample Calculation (Zone 2, V = 450 gallons):
Current Standard:
/
5
/
5 450 293.62 294
Proposed Standard:
/
3.75 40
/
3.75 450 40 260.21 260
Proposed Standard + Label:

/
3.75 40
5%
/
3.75 450 40 260.21
105
260.21 5% 13.01
260.21 13.01 247.2
Figure B-1: Maximum Allowable Standby Power per Zone
The baseline average energy consumption of the appliance is the estimate of energy
consumed by the market representative ratio of compliant and non-compliant units. For
example, the annual energy consumption of a portable electric spa is calculated by
multiplying the average maximum allowable standby power by the duty cycle and by the
compliancy rate for each zone. Table B-10 lists the baseline energy consumption without
the labeling impact for the purpose of explaining the calculations in this study.
106
Table B-10: Baseline Energy Consumption without label savings
Sales
Non- Weighted
Compliant Total
Compliant Average
Zones Energy Use Energy Use
Energy Use Energy
(Wh/yr) (Wh/yr)
(Wh/yr) Consumption
(Wh/yr)
1A* 1,173,402 59,130 1,232,532 61,627

1B 1,359,683 272,199 1,631,883 463,455
2 1,482,718 898,829 2,381,546 1,485,370
3 1,621,914 1,704,021 3,325,935 47,893
4* 187,026 4,302,474 4,489,500 3,592
5 3,271,860 1,338,090 4,609,950 31,348
6 4,234,128 874,371 5,108,499 60,791
7 2,190,000 4,099,680 6,289,680 26,417
8 3,595,104 3,009,936 6,605,040 27,741
Zone 2 in this table will be used as the basis of explaining the calculations in this study.
Sample Calculations (Zone 2):
Proposed Standard:
260 8,760 0.651 1,482,718 /
Current Standard:
294 8,760 0.349 898,829 /
Total Energy Consumption for Zone 2:
2 1,482,718 898,829 2,381,546 /
The baseline average energy consumption for portable electric spas was calculated by
multiplying the energy consumption by the percent of units in each zone.
# %
2,381,546 / 0.6237 1,485,370 /
107
The annual stock energy consumption for portable electric spas is the product of average
energy consumption and the annual stock in 2017.
. 2017 10
1,485,370 596,776 10 886
The total annual stock energy consumption is the addition of the annual stock energy
consumption for each zone. Table B-11 lists the baseline total annual stock energy
consumption for years 2017 and 2026. Calculations for year 2026, when full
implementation is complete, are similar.
Table B-11: Baseline Energy Use

Year Stock Total Annual Energy Consumption (GWh/yr)
2017 596,776 1,318
2026 756,527 1,671
Compliant Energy Use

The power consumption of compliant products is estimated based on minimum
requirements to meet the proposed regulations. The annual energy consumption is
calculated using the same methodology as baseline energy use. Table B-12 lists the
compliant total annual stock energy consumption for years 2017 and 2026.
Table B-12: Compliant Energy Use

Year Stock Total Annual Energy Consumption (GWh/yr)
2017 596,776 1,313
2026 756,527 1,609
Cost and Savings

Table B-13 lists the energy savings for portable electric spas once the proposed standard
becomes effective in 2017and when complete implementation has occurred in 2026.
108
Table B-13: Standby Power Standard Statewide Annual Stock Savings
First‐Year Savings Complete Turnover Savings
Energy Savings Energy Savings
Consumption ($ Million) Consumption ($ Million)
(GWh/yr) (GWh/yr)
Portable Electric 4.2 (87%) 0.7 53 (87%) 9
Spas (Zones 1‐3)
Exercise Spas 0.6 (13%) 0.1 8 (13%) 1
(Zones 4‐8)
Total 4.8 (100%) 0.8 61 (100%) 10
The energy savings are calculated by subtracting the compliant energy use from the
baseline energy use.
Sample Calculation:
1,317.84 1,313 4.84
The cost savings (benefits) are calculated by multiplying the annual energy savings by
$0.1619 per kWh.
$0.1619

Sample Calculation:
$0.1619 10
4.84 $783,596 $0.78
1
The cumulative energy and costs savings when the proposed standard has reached
complete implementation is the summation of savings from each year beginning in 2017
and ending in the year 2026.
Table B-14 lists the energy savings and cost savings for labeled portable electric spas once
the proposed standard becomes effective in 2017 and when complete implementation has
occurred in 2026. The savings in the table below assumes the standard is completely
implemented for the first-year and after complete turnover.
Table B-14: Statewide Annual Stock Savings Adjusting for Label Impact
First-Year Savings Complete Turnover Savings
Energy Energy
Savings Savings
Consumption Consumption
(GWh/yr) (GWh/yr)
Portable Electric 5.7 0.9 69.6 11.2
Spas
Exercise Spas 0.8 0.1 10.4 1.8
Total 6.5 1.0 80 13
109
The total energy consumption savings are calculated by applying the 5 percent potential
label savings to the total compliant annual energy consumption for 2017 and 2026 (refer to
Table B-11 and Table B-12).

100% 5%
10%

100% 5%
Sample Calculation:
100% 5% 10%
1313 6.5 /
100 100 100
100% 5%
1609 80
100 100
The energy consumption savings for each type of portable electric spa (i.e., portable electric
spas and exercise spas) is calculated by using the ratio of the energy consumption savings
of each type to the total energy consumption savings based on the standby power standard
only (see Table B-13) and then applying it to the total energy consumption savings from the
label savings (Table B-14). Table B-15 summarizes the ratio for each type of portable
electric spa.
Table B-15: Percentage of Energy Consumption after Applying the Standby Power Standard
Type Percentage
Portable Electric Spas 87%
Exercise Spas 13%
87%
13%
Sample Calculation:
13%
80 10.4
100
The cost savings are calculated by multiplying the energy consumption savings by the
California retail price of electricity.
$0.1619

Sample Calculation:
$0.1619
80 $13
110
Table B-16 lists the weighted unit energy savings, lifecycle costs, and lifecycle benefits.
Table B-16: Weighted Unit Energy Savings and Lifecycle Benefits/Costs

Design Energy Lifecycle Lifecycle Lifecycle
Life Savings Costs Benefit Benefit/Cost
(years) (kWh/year) ($/unit) ($/unit) Ratio
Portable Electric Spas 10 317 $ 100.38 $ 512 5
Exercise Spas 10 1,451 $ 100.38 $ 2,349 23
The calculation for energy savings per unit is the difference between the baseline and
compliant consumption per unit which is similar to the calculations in the previous steps.
The lifecycle benefit is the product of the energy savings per unit, the life of unit, and the
average retail price of electricity.
The total set-up cost is calculated by multiplying the set-up cost for each manufacturer by
the number of manufacturers in the MAEDBS system.
The total printing costs to label stock are calculated by multiplying the printing cost per
label by the stock in 2017.
$0.22 2017
The total labor costs are calculated by multiplying the total time to adhere labels to the
entire stock by the packaging and filling machine operators’ hourly wage.
2017
The total cost to label stock is the addition of total set-up cost, total printing costs, and
total labor costs.
The label cost for each portable electric spa is calculated by dividing the total cost to label
stock by the 2017 stock.

2017
Table B-17 lists approximate water surface area’s based on the average volume of each zone
and the evaporation rate based on the approximate water surface area.
111
Table B-17: Evaporation Rate without a Spa Cover
Unit Volume Water Evaporation

Zone Capacity Surface Rate127, wp
(gallons) Area (m2) (gallons/hr)
Zone 1A 140 3.3 0.70

Zone 1B 240 3.9 0.83
Zone 2 450 5.7 1.21
Zone 3 750 5.8 1.23
Zone 4 1,050 8.0 1.69
Zone 5 1,350 8.7 1.85
Zone 6 1,650 10.9 2.31
Zone 7 1,950 13.0 2.76
Zone 8 2,250 14.0 2.96
The evaporation rate is determined from using an equation found in the Design
Considerations for Pools and Spas (Natatoriums) by John W. Lund.
0.089 0.0782
Y
where,
wp=evaporation rate (kg/s)
A=area of pool surface (m2)
pw=saturation vapor pressure taken at surface water temperature (kPa), 6.95 kPa
pa=saturation pressure at room air dew point (kPa), 1.768 kPa
V=air velocity over water surface (m/s), 0.1 m/s
Fa=activity factor, 1
Y=latent heat required to change water to vapor, 2257 kJ/kg
Staff Sample Calculations for Zone 2 (Average Volume =450 gallons):
5.7 6.95 1.768 0.089 0.0782 0.1 1

0.001267
2257
Convert kilogram per second to gallons per hour

0.26417 60 60
0.001267 1.21
1 1 1
127 Lund, John W., Design Considerations for Pools and Spas (Natatoriums). Klamath Falls: Geo-Heat Center Oregon
Institute of Technology, 2000.
112
Table B-18 lists the total energy and the total power required to heat a certain amount of
water. In this case, this amount of water is an assumption of how much water would
evaporate due to not having a spa cover.
Table B-18: Total Energy and Power Required to Heat Evaporated Water
Energy Energy Total
Evaporation Total
Required to Required to Power
Rate, wp Energy128
Heat Water Vaporize Required
(gallons) (kJ)
to 104°F (kJ) Water (kJ) (kW)
0.5 185 4,272 4,456 1
1 369 8,544 8,913 2
2 738 17,088 17,826 5
3 1,107 25,632 26,739 7
4 1,476 34,176 35,652 10
5 1,845 42,719 44,565 12
The energy required to heat water to 102°F is calculated by using the specific heat
relationship.
∙ ∙∆
where,

, 4.186

∆
15.6 60
38.89 102
The energy required to vaporize water is based on the latent heat.
∙
where,

, 2257
128 Stein, Benjamin. Building Technology: Mechanical and Electrical Systems. New York: John Wiley and Sons, Inc.,
1997.
113
The total energy is calculated by adding the energy to heat water to 102°F and the energy to
vaporize water.

The total power required is the total energy over a period of an hour.

3600
Table B-19 lists the annual energy consumption and annual water consumption based on
the total power required to heat the evaporated water listed.
Table B-19: Annual Energy and Water Consumption
Water
Evaporation Energy Energy
Water Wasted Costs
Rate, wp Consumption Costs
(gallons/year) ($/1000
(gallons/hr) (kWh/year) ($)
gallons)
0.5 10,844 4,380 33 1,756

1 21,688 8,760 66 3,511
2 43,376 17,520 131 7,023
3 65,064 26,280 197 10,534
Source: Building Technology: Mechanical and Electrical Systems by B. Stein.
The energy consumption is calculated by multiplying the total power by the duty cycle.
8,760
The water wasted or water loss is calculated by multiplying the evaporation rate by the duty
cycle.
8,760
The energy costs are calculated by multiplying the energy consumption by the average retail
price of electricity.
$0.1619
The water costs are calculated by multiplying the water loss by the delivery charge and
treatment charge of water.
$2.82 $4.66

1000 1000
114

TN210066 20160128T103017 Analysis of Efficiency Standards For Pool Pumps and Motors and

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TN210066 20160128T103017 Analysis of Efficiency Standards For Pool Pumps and Motors and

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DOCKETED

Docket Number: 15-AAER-02

California Energy Commission

January 2016 | CEC-400-2016-002-SD

Dave Ashuckian, P.E.

On March 25, 2013, the Energy Commission released an “Invitation to Participate” to

Keywords: Appliance Efficiency Regulations, appliance regulations, energy efficiency, pool

Please use the following citation for this report:

TABLE OF CONTENTS ............................................................................................................................ iii

List of Figures ............................................................................................................................................ vi

List of Tables ............................................................................................................................................ vii

Executive Summary .................................................................................................................................1

CHAPTER 1: Legislative Criteria ..............................................................................................................2

CHAPTER 2: Efficiency Policy ..................................................................................................................3

Part A: Pool Pumps and Motors ............................................................................................................ 6

CHAPTER 3: Product Description ...........................................................................................................7

CHAPTER 4: Regulatory Approaches .................................................................................................. 16

CHAPTER 5: Alternative Consideration .............................................................................................. 19

CHAPTER 7: Savings and Cost Analysis ............................................................................................. 30

CHAPTER 9: Environmental Impacts .................................................................................................. 38

CHAPTER 10: Regulatory Language .................................................................................................... 40

APPENDIX A: Staff Assumptions and Calculation Methods........................................................... 48

Part B: Portable Electric Spas .............................................................................................................. 62

Chapter 11: Product Description ......................................................................................................... 63

Chapter 13: Alternative Considerations............................................................................................. 79

Chapter 15: Savings and Cost Analysis .............................................................................................. 86

Chapter 17: Environmental Impacts ................................................................................................... 95

Chapter 18: Regulatory Language ....................................................................................................... 96

Appendix B: Staff Assumptions and Calculation Methods ............................................................ 99

The California Energy Commission proposes to create significant energy efficiency

Reducing Electrical Energy Consumption to Address Climate

Loading Order for Meeting the State’s Energy Needs

 All new residential construction in California will be zero-net-energy (ZNE) by 2020.

Governor’s Clean Energy Jobs Plan

Overview of Pool Water Circulation System

Figure 1: Standard pool pump system installation schematic

Figure 2: Pool Plumbing System Complete with Filter, Heater, Skimmer,

Illustration Credit: Staff Illustration

Pump and Motor Equipment Description

Source: Hayward Pools

Figure 4: Replacement Pool Pump Motor

Source: Century A.O. Smith

Pool Circulation System Energy Consumption

Pump Affinity Law 1 Flow Rate (gallon per minute)

Pump Affinity Law 2 Head or Pressure (psi)

Pump Affinity Law 3 Power (kW or hp)

Motor Energy Consumption and Efficiency

28 Pump Affinity Laws, The Engineering Toolbox, available at http://www.engineeringtoolbox.com/affinity-laws-

Source: Small Motors and Motion Association

Pool Pump and Motor Categories

Regulations in Other States

The CASE Report

Alternative 1: Maintaining Current Title 20 Appliance

Alternative 2: Incorporate CASE Team Proposal

Figure 6: CASE Report Single-Speed Efficiency Standard

Alternative 3: Incorporate CASE Team Proposal with Tiered

While Alternative 3 provides significant savings, Alternative 4 proposes more stringent

Single-Speed (up to 1 hp) (0.08*hp3450+0.62)*100% N/A

Table 3: Alternative 3, Tier II - Effective January 1, 2021

Single-Speed (up to 1 hp) (0.08*hp3450+0.62)*100% N/A

Alternative 4: Incorporate CASE Team Proposal with Uniform

As discussed in the following section, staff believes that Alternative 4 is cost-effective,

Table 4: Staff Proposed Alternative 4, Tier I - Effective January 1, 2018

Single-Speed (up to 1 hp) (0.08hp3450+0.62)100% N/A

Single-Speed (up to 1 hp) (0.08hp3450+0.62)100% N/A